The article discusses the case of Cunningham v. California and how the Supreme Court rejected as unconstitutional California sentencing law. Professor Jeffrey L. Fisher is quoted.

"It gives them some work," said Stanford Law School scholar Jeffrey L. Fisher, who argued and won Blakely. Fisher noted that 10 other states have gone through the same process after the high court forced sentencing reappraisals. "None found it terribly difficult," he said. "Obviously, California has more people and more defendants, but it also has more courts and more judges."