Furthermore, removing these determinations from the jury's purview was not consistent with the role of the jury in the 18th century, which had tremendous control over the punishment a defendant would suffer. Thus, to avoid any unnecessary tension with Mullaney, Patterson, and McMillan, the Court held that these facts were elements of separate federal carjacking crimes.
The exclusion of certain determinations from jury consideration was at odds with 18th-century jury practices regarding punishment. To align with Mullaney, Patterson, and McMillan, the court determined that these facts are essential components of separate federal carjacking crimes.