 "Blakely" and "United States v. Booker", for example, involved sentencing schemes in which the judge was required to impose a sentence within a range determined both by the crime of conviction and additional facts.In those schemes, if the judge chose a sentence above that range, or chose one from a higher range, the facts that allowed the judge to do so had to be submitted to a jury and proved beyond a reasonable doubt.Under California's DSL, the middle term is the "statutory maximum" sentence for "Blakely" purposes.