 Furthermore, the "Black" court noted that under California law, sentencing enhancement, which are distinct from aggravating factors, did have to be proved beyond a reasonable doubt.These two differences, it reasoned, meant that the DSL survived "Blakely".But "Apprendi" set forth a bright-line rule that did not tolerate "trivial" incursions in the name of preserving the "basic" jury-trial right of the criminal defendant.