Blakely v. Washington
Is it still good law? What later courts have actually done to this case.
Status
More on how this was screened
Most deny retroactive relief on collateral review, including cases involving belated appeals or correction of otherwise final sentences. Other decisions decline to extend the jury-finding requirement to consecutive-sentence findings, ordinary supervised-release revocation, or restitution. Reversed and vacated rulings were excluded.
13,215 later cases cite Blakely v. Washington; 1,098 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.
Relying on Blakely v. Washington?
This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.
Treatments
Limited
-
Held that Blakely does not apply retroactively to cases on collateral review.
McBride v. State · Florida Fourth District Court of Appeal · filed
We further hold that Blakely does not apply retroactively to cases on collateral review.
Read the full opinion on CourtListener → -
Held that Blakely does not require jury findings before the court orders consecutive sentences under Tennessee law.
State of Tennessee v. Cedric Anthony · Tennessee Court of Criminal Appeals · filed
It appears that Blakely concerns do not apply to the trial court’s decision to impose consecutive sentencing under our sentencing scheme. Defendant is not entitled to relief on this issue.
Read the full opinion on CourtListener → -
Held that Blakely would not apply retroactively to cases on collateral review even if it governed the federal sentencing guidelines.
Price v. United States · Tenth Circuit · filed
Further, even if Blakely does apply to the federal guidelines, it will not apply retroactively to cases on collateral review.
Read the full opinion on CourtListener → -
In an unpublished judgment entry, the court held Blakely unavailable retroactively on collateral review.
State v. Merriweather · Ohio Court of Appeals, First District (unpublished) · filed
Merriweather raises sentencing issues, and, arguably, Blakely v. Washington (2004), ___ U.S. ___, 124 S.Ct. 2531 , and United States v. Booker (2005), ___ U.S. ___, 125 S.Ct. 738 , set forth an applicable federal or state right. Nevertheless, those cases apply to "all cases on direct review or not yet final." State v. Bruce, 1st Dist. No. C-040421, 2005-Ohio-373 . They do not apply retroactively to cases on collateral review. Humphress v. United States (C.A.6, 2005), 398 F.3d 855 ; Green v. United States (C.A.2, 2005), 397 F.3d 101 .
Read the full opinion on CourtListener → -
The court held Blakely inapplicable to judicial findings supporting consecutive sentences for separate crimes.
State v. Pelletier · Ohio Court of Appeals, Third District (unpublished) · filed
Even if the reasoning of Blakely were applicable to Ohio felony sentencing, we do not find that appellant's sentence is in conflict with that decision. The Apprendi and Blakely holdings concern the limitations for punishment for one conviction and have no application as to whether sentences for multiple, separate crimes should be served concurrently or consecutively. In the absence of such a holding, we find that the trial court's determination that appellant's sentences should be served consecutively was not a violation of Apprendi or Blakely.
Read the full opinion on CourtListener → -
Held that Blakely was unavailable retroactively to challenge a sentence imposed in 1990.
State v. Webb · Ohio Court of Appeals, Eighth District · filed
Webb was sentenced on March 15, 1990, nearly 15 years before the United States Supreme Court decided Blakely. Since the decision in Blakely was announced, numerous federal courts have declined to apply Blakely retroactively. ... no combination of cases necessarily dictate retroactivity of the Blakely decision. ... Webb's third assignment of error is therefore overruled.
Read the full opinion on CourtListener → -
The court held that Blakely supplied no retroactive right permitting an untimely collateral challenge to consecutive sentences.
State v. Cruse · Court of Appeals of Ohio, Tenth District (unpublished) · filed
Given all of the foregoing, Blakely does not represent the recognition of a new federal or state right that applies retroactively to appellant. Thus, appellant has not demonstrated that his petition for post-conviction relief should be entertained, despite its untimeliness, pursuant to the exception found in R.C. 2953.23 (A)(1). Because he has not done so, the trial court was without jurisdiction to entertain his untimely petition for post-conviction relief. State v. Raines, Franklin App. No. 03AP-1076, 2004-Ohio-2524. Therefore, the trial court did not err in dismissing appellant's petition as untimely.
Read the full opinion on CourtListener → -
The court applied Blakely’s nonretroactivity on collateral review when rejecting the claimed prejudice from counsel’s failure to appeal.
Rafael DeJesus Medina v. United States · Eleventh Circuit (unpublished) · filed
Additionally, as the district court observed, Medina’s filing of this § 2255 motion occurred only after the Supreme Court issued its decision in Blakely, which Medina also relied upon in seeking § 2255 relief, and which we have concluded is not applicable to cases on collateral review. See Varela, 400 F.3d at 866-68.
Read the full opinion on CourtListener → -
The court denied Blakely resentencing because the conviction became final before the nonretroactivity cutoff adopted in State v. Allen.
State v. Simpson · North Carolina Court of Appeals · filed
In this case, Defendant contends the use of a sentencing aggravating factor that was neither submitted to a jury nor stipulated by Defendant constituted a Blakely error. Because Defendant’s case was final as of 23 December 2003, Allen requires us to hold that he is not eligible for a new sentencing hearing.
Read the full opinion on CourtListener → -
The court declined to extend Blakely’s jury-trial and reasonable-doubt requirements to ordinary supervised-release revocation proceedings.
United States v. Rasheim Carlton · Second Circuit · filed
Thus, in contrast to the defendants in Apprendi, Blakely, and Booker, Carlton stands already convicted of the underlying offense, and any rights he might have had as described in those cases have been pared down to “conditional liberty,” the existence of which depends on defendant’s observing the limitations of his supervised release. For these reasons, we must reject appellant’s constitutional challenge to 18 U.S.C. § 3583(e)(3).
Read the full opinion on CourtListener → -
The court held Blakely unavailable retroactively in a successive postconviction petition.
State v. Mitchell · Ohio Court of Appeals, Second District (unpublished) · filed
In his second assignment of error, Mitchell claims that the trial court erred in sentencing him to a non-minimum sentence. Again, he relies on the United States Supreme Court's decision in Blakely v. Washington. As we discussed under the first assignment of error, Blakely does not apply retroactively, and Mitchell waived his right to appeal his sentence. Thus, the court properly concluded that Mitchell's petition set forth no substantive grounds for relief.
Read the full opinion on CourtListener → -
The court held that Blakely announced a new procedural rule that does not apply retroactively on collateral review.
People v. Wenzinger · Colorado Court of Appeals · filed
Because the rule announced in Blakely is a new rule of criminal procedure that does not apply retroactively to cases on, collateral review, we uphold the trial court's ruling.
Read the full opinion on CourtListener → -
The court held that Blakely did not apply retroactively to a final sentence imposed in 2001.
State v. McHale · Ohio Court of Appeals, Second District (unpublished) · filed
McHale insists that the United States Supreme Court's holding in Blakely v. Washington (2004), 542 U.S. 961 , 124 S.Ct. 2531 required the trial court to order only a minimum sentence because he was a first-time offender who had never before served a prison term. However, the court also has limited Blakely's holding to cases already on direct appeal or pending before a trial court. United States v. Booker (2005), 543 U.S. 220 , 125 S.Ct. 738 . Because the holding is not retroactive, it cannot be applied in this case.
Read the full opinion on CourtListener → -
Held that Blakely did not apply retroactively to permit this untimely postconviction challenge.
State v. McKinney · Court of Appeals of Ohio, Ninth District (unpublished) · filed
As stated herein, in Booker, supra, the United States Supreme Court limited its holdings in Blakely and Apprendi to cases on direct review. Similarly, in Foster, the Ohio Supreme Court restricted retroactive application of its holding to cases on direct review. Appellant's case is before us on appeal from a denial of his petition for post-conviction relief, not from direct appeal. As such, appellant has failed to meet his burden under R.C. 2953.23 (A)(1) to file a timely petition for post-conviction relief and the trial court therefore lacked jurisdiction to entertain the petition. ... In this case too, appellant's case is before this Court on appeal from a denial of his petition for post-conviction relief, not from a direct appeal. Accordingly, for the reasons enunciated above, appellant has failed to meet his burden under R.C. 2953.23 (A)(1) to file a timely petition for post-conviction relief and the trial court therefore lacked jurisdiction to entertain the petition. Further, although the trial court did not enunciate its reasons for its denial of the petition, this Court finds that the denial was proper because the court was not statutorily authorized to entertain the untimely petition. Appellant's second assignment of error is overruled.
Read the full opinion on CourtListener → -
Held that Blakely supplied no retroactive right permitting the untimely petitions for postconviction relief.
State v. Jones · Court of Appeals of Ohio, Tenth District (unpublished) · filed
As noted, appellant contends he is entitled to relief under the provisions of R.C. 2953.23 (A)(1)(a) based upon the United States Supreme Court's decision in Blakely , supra. We disagree. This court has previously held that " Blakely does not recognize a new federal or state right that applies retroactively." State v. Graham , Franklin App. No. 05AP-588, 2006-Ohio-914 , at ¶ 10 , citing State v. Myers , Franklin App. No. 05AP-228, 2005-Ohio-5998 . This court has similarly held that the Ohio Supreme Court, in Foster , supra, "applied its holding only to cases pending on direct review." State v. Williams , Franklin App. No. 05AP-339, 2006-Ohio-2197 , at ¶ 28 . See, also, State v. Harris , Sandusky App. No. S-05-014, 2006-Ohio-1395 , at ¶ 16 ("the federal cases, as well as Foster , the recent decision by the Ohio Supreme Court holding that certain statutes in Ohio's sentencing scheme violate the Sixth Amendment to the United States Constitution, are not applicable to a petition for postconviction relief").
Read the full opinion on CourtListener → -
Held that Blakely does not apply retroactively to this collateral challenge to a final sentence.
State v. Lopez · Court of Appeals of Ohio, Fifth District (unpublished) · filed
The United States Supreme Court has not made the decision in Blakely v. Washington (2004) , 542 U.S. 296 , 124 S.Ct. 2531 , 159 L.Ed.2d 403 retroactive to cases already final on direct review. This Court, as well as numerous other courts around the State, has found Blakely does not apply retroactively to cases already final on direct review. State v. Craig , Licking App. No. 2005CA16, 2005-Ohio-5300 ; State v. Myers , Franklin App. No. 05AP-228, 2005-Ohio-5998 (concluding Blakely does not apply retroactively to cases seeking collateral review of a conviction); State v. Cruse , Franklin App. No. 05AP-125, 2005-Ohio-5095; State v. Stillman , Fairfield App. No. 2005-CA-55, 2005-Ohio-6299 (concluding U.S. Supreme Court did not make Blakely retroactive to cases already final on direct review).
Read the full opinion on CourtListener → -
Held that Blakely does not apply retroactively to this collateral challenge to a final sentence.
State v. Lipsey · Court of Appeals of Ohio, Tenth District (unpublished) · filed
We agree with the reasoning of both In re Dean and Webb . The Blakely decision does not apply retroactively to cases on collateral review. Therefore, even if Blakely had recognized a new right, that decision is not applicable to appellant's collateral attack upon his conviction and sentence.
Read the full opinion on CourtListener → -
Held that Blakely does not apply retroactively to this collateral challenge to a final sentence.
State v. Macias · Court of Appeals of Ohio, Second District (unpublished) · filed
Blakely and Booker are applicable to cases on direct review. Booker at 125 S.Ct. 769 . As observed by the trial court, Macias' case was no longer pending on direct review when he moved for post-conviction relief. {¶ 10} Based on the foregoing, the fourth assignment is overruled. While the second and third assignments contain correct statements, no remedy exists under R.C. 2953.23 where Booker and Blakely have no application to cases no longer under direct review, and these assignments are overruled. The first assignment is overruled as moot.
Read the full opinion on CourtListener → -
Held that Blakely could not apply retroactively to certiorari review of a conviction already final when Blakely was decided.
State v. Hasty · Court of Appeals of North Carolina · filed
Here, defendant’s case was final in 1998, when his plea of guilty was accepted and judgment entered. Defendant did not take a direct appeal from that judgment, but rather moved for a writ of certiorari from this Court in 2002. As defendant’s case was not pending on direct review and was final at the time the rule in Blakely was issued, the rule cannot be retroactively applied to defendant’s appeal before this Court by writ of certiorari. See State v. Pender, 176 N.C. App. 688, 693-94, 627 S.E.2d 343, 347 (2006).
Read the full opinion on CourtListener → -
Held that Blakely did not create a retroactively applicable right permitting a delayed postconviction petition.
State v. Dunn · Court of Appeals of Ohio, Fourth District (unpublished) · filed
But, because the United States Supreme Court's decisions in Apprendi, Blakely, Booker , and their subsequent Ohio counterpart, Foster , did not create any new constitutional rights that apply retroactively to cases that are not on direct review, they cannot satisfy the first condition of R.C. 2953.23 (A)(1). State v. Barney , Meigs App. No. 05CA11, 2006-Ohio-4676 , at ¶ 8-¶ 11 . Thus, Dunn failed to satisfy the first condition of R.C. 2953.23 (A)(1).
Read the full opinion on CourtListener → -
Held that Blakely does not apply retroactively to the collateral challenge to Holton’s final sentence.
State v. Holton, 06ca28 (5-4-2007) · Court of Appeals of Ohio, Fourth District (unpublished) · filed
Additionally, in United States v. Booker (2005), 543 U.S. 220 , 125 S.Ct. 738 , 160 L.Ed.2d 621 , the United States Supreme Court restricted its holdings in Blakely and Apprendi to cases on direct review. Similarly, in Foster , the Ohio Supreme Court limited application of its holdings to cases on direct review or not yet final. Id. at ¶ 106. An appeal from a denial of a petition for post-conviction relief does not constitute a direct appeal for purposes of applying Foster. State v. Gopp , Wayne App. No. 06CA0034, 2006-Ohio-5477 , at ¶ 10 . Blakely and Foster are thus inapplicable. State v. Pryor , Fairfield App. No. 06CA28, 2006-Ohio-6724 , at ¶ 13 ; State v. Williams , Franklin App. No. 05AP-339, 2006-0hio-2197, at ¶ 28.
Read the full opinion on CourtListener → -
Held that Blakely does not apply retroactively on collateral review because it meets neither Teague exception.
State v. Chaney, 88529 (5-10-2007) · Court of Appeals of Ohio, Eighth District (unpublished) · filed
The second exception applies only narrowly to procedures "central to an accurate determination of innocence or guilt." Teague , 489 U.S. at 313 . Certainly, the factual basis for sentencing is not central to a determination of guilt or innocence. Therefore, Blakely and Foster do not apply retrospectively to cases on collateral review.
Read the full opinion on CourtListener → -
Held that Blakely does not apply retroactively to a sentence already final on direct review.
State v. Tapp, 07caa010003 (8-22-2007) · Court of Appeals of Ohio, Fifth District (unpublished) · filed
This Court as well as numerous other state and federal courts have found Blakely does not apply retroactively to cases already final on direct review. ... It is undisputed that appellant's sentence was final prior to the filing of the appeal herein. While we acknowledge appellant's argument, we adhere to our decision in Clark. As noted by the Supreme Court of Ohio in Foster at ¶ 5, the Apprendi rule was broadened in Blakely.
Read the full opinion on CourtListener → -
Held that Blakely does not require a jury to determine restitution because Colorado statutes prescribe no maximum amount.
People v. Smith · Court of Appeals of Colorado · filed
We are persuaded by the rationale of these cases and apply it here. Because Colorado's restitution statutes do not prescribe a maximum restitution amount, we conclude that the rule of Apprendi and Blakely does not apply to restitution orders. Section 18-1.8-205 states that "the court shall order that the defendant make full restitution" (emphasis added), and this includes the victim's pecuniary losses and all out-of-pocket expenses. According to § 18-1.3-602(8)(a), restitution is not limited by the jury's findings but includes the pecuniary loss suffered by the victim including, but not limited to, all out-of-pocket expenses and other losses or injuries proximately caused by an offender's conduct. Thus, we reject defendant's Sixth Amendment argument.
Read the full opinion on CourtListener → -
Held that Blakely applies only on direct review and does not permit this collateral resentencing claim.
State v. Dille, 2006-Ca-10 (8-24-2007) · Court of Appeals of Ohio, Fifth District (unpublished) · filed
Appellant has made no such demonstration in his application for reconsideration. Appellant argues that sentencing errors are cognizable in post-conviction relief proceedings. However, as noted above and in our opinion previously filed, both the Ohio Supreme Court and the United States Supreme Court have explicitly held that Blakely and Foster arguments apply only to case on direct, not collateral, review.
Read the full opinion on CourtListener → -
Held that Blakely is not retroactive to a final sentence challenged on collateral review.
State v. Smith · Court of Appeals of Ohio, Fourth District (unpublished) · filed
Here, we agree with the trial court that it lacked jurisdiction to consider Smith's petition. Smith did not directly appeal his underlying possession of drugs sentence. Thus, any right created in Apprendi, Blakely , or Foster is not retroactive to his situation because his case is on collateral review, not direct review. See Gondor , supra, at 387-388, quoting State v. Steffen (1994), 70 Ohio St.3d 399 , 410 ("A post-conviction proceeding is not an appeal of a criminal conviction, but, rather, a collateral civil attack on the judgment."). Because Smith failed to comply with R.C. 2953.23 (A)(1)(a), we do not need to consider R.C. 2953.23 (A)(1)(b).
Read the full opinion on CourtListener → -
The court held Blakely unavailable on collateral review of a conviction that was already final.
State v. Barber, 21837 (10-19-2007) · Ohio Court of Appeals, Second District · filed
Even if Blakely was a new rule, this Court would not be required to apply it to those cases which came to us upon collateral review such as a post-conviction relief petition because Apprendi did not announce a "watershed rule of criminal procedure," implicating the fundamental fairness and accuracy of the criminal proceeding. See Schriro v. Summerlin , 542 U.S. 348 , 355-56 , (2004).
Read the full opinion on CourtListener → -
The court held that a later grant of certiorari did not make Blakely available to a conviction finalized before Blakely was decided.
State v. Talley · North Carolina Court of Appeals (unpublished) · filed
Accordingly, Defendant's case was final, although only by a few days, prior to the 24 June 2004 decision in Blakely. Moreover, even though we granted Defendant's 3 July 2006 petition for writ of certiorari, Defendant's case was still final prior to the Blakely decision. See Coleman, ___ N.C. App. at ___, 640 S.E.2d at 786 (citing Hasty, ___ N.C. App. at ___, 639 S.E.2d at 96) (recognizing that "the granting of a petition for writ of certiorari does not alter the determination of when a case becomes final."). Therefore, Defendant is not entitled to Blakely review, and we overrule the assignments of error grouped under this argument.
Read the full opinion on CourtListener → -
The court held that Blakely did not apply retroactively to the prisoner’s collateral habeas claim.
Ricky Thomas Hughes v. Roland Olson, Warden · Tennessee Court of Criminal Appeals · filed
This Court has held, however, that Blakely does not apply retroactively to cases on collateral appeal. See Richard C. Anderson v. Howard Carlton, No. E2007-01465-CCA-R3-HC, 2008 WL 110084, at *2 (Tenn. Crim. App., at Nashville, Jan. 11, 2008), no Tenn. R. App. P. 11 application filed. ... The Petitioner is not entitled to relief on these issues.
Read the full opinion on CourtListener → -
The court held Blakely nonretroactive when rejecting an untimely postconviction petition.
State v. Brooks, 08ap-585 (11-13-2008) · Ohio Court of Appeals, Tenth District · filed
Brooks also failed to demonstrate in his petition that the United States Supreme Court recognized a new federal or state right that applied retroactively to him. Brooks alludes in his brief that his petition relies on Blakely v. Washington (2004), 542 U.S. 296 , 124 S.Ct. 2531 . This court has repeatedly held that Blakely is not retroactive. State v. Graham , Franklin App. No. 05AP-588, 2006-Ohio-914 . Appellant's second assignment of error is likewise overruled.
Read the full opinion on CourtListener → -
The court held that Apprendi and Blakely did not apply retroactively in this collateral proceeding.
Harris v. Hill · Oregon Court of Appeals · filed
The principles announced by the Court in Apprendi and Blakely do not apply retroactively in a collateral proceeding such as this one, and counsel’s failure to anticipate Apprendi’s holding does not constitute inadequate assistance of counsel. Miller, 340 Or at 16-17; Page v. Palmateer, 336 Or 379, 84 P3d 133 (2004); see also Schriro v. Summerlin, 542 US 348, 124 S Ct 2519, 159 L Ed 2d 442 (2004) (jury trial right set forth in Apprendi does not apply retroactively in collateral proceedings).
Read the full opinion on CourtListener → -
The court applied the existing nonretroactivity rule to reject collateral relief under Blakely despite a request to reconsider that rule after Danforth.
Frias v. Coursey · Oregon Court of Appeals · filed
On appeal, petitioner argues that the trial court erred in dismissing his petition because Blakely and Apprendi apply retroactively on collateral review. Petitioner concedes that the Oregon Supreme Court has previously held to the contrary. Miller v. Lampert, 340 Or 1, 125 P3d 1260 (2006) (adhering to its conclusion in Page v. Palmateer, 336 Or 379, 84 P3d 133 (2004), that Apprendi does not apply retroactively). Nonetheless, he contends that Miller was wrongly decided in light of the United States Supreme Court’s decision in Danforth v. Minnesota, 552 US 264, 128 S Ct 1029, 169 L Ed 2d 859 (2008). In petitioner’s view, Danforth specifically calls into question the reasoning in Miller and Page. See Danforth, 128 S Ct at 1039 n 14 (describing the decision in Page as “misguided”). Whatever the merits of petitioner’s argument, it is properly addressed to the Oregon Supreme Court. Affirmed.
Read the full opinion on CourtListener → -
The court applied Blakely’s nonretroactivity as an additional ground for denying collateral habeas relief.
Joseph B. Thompson v. Tony Parker, Warden (State of Tennessee) · Tennessee Court of Criminal Appeals · filed
The Petitioner’s argument that the trial court illegally enhanced his sentences in violation of Blakely v. Washington, 542 U.S. 296, 124 S. Ct. 2531 (2004), does not entitle him to habeas corpus relief. ... Moreover, this Court has repeatedly held that Blakely does not apply retroactively to cases on collateral appeal. See Timothy R. Bowles, 2007 WL 1266594, at *2-3; Billy Merle Meeks, 2007 WL 4116486, at *7; James R.W. Reynolds v. State, No. M2004-02254-CCA-R3-HC, 2005 WL 736715, at *2 (Tenn. Crim. App., at Nashville, Mar. 31, 2005), perm. to appeal denied (Tenn. Oct. 10, 2005).
Read the full opinion on CourtListener → -
The court denied federal habeas relief under Blakely because the conviction became final before Blakely was decided.
Paul Remme v. Jean Hill · Ninth Circuit (unpublished) · filed
Although this sentence did, in fact, violate the Sixth Amendment under Blakely, it does not entitle Remme to federal habeas relief because his conviction became final before the Supreme Court issued its decision in Blakely, and Blakely does not apply retroactively. Schardt v. Payne, 414 F.3d 1025, 1038 (9th Cir. 2005).
Read the full opinion on CourtListener → -
The court held that restoring a belated direct appeal did not make Blakely retroactively available to a conviction already final when the original appeal period expired.
Sakar v. State · Alaska Court of Appeals · filed
Even when a defendant pursues post-conviction relief and obtains the right to file a late appeal, the defendant’s conviction should still be considered “final” for retroactivity purposes when the defendant’s original time for filing an appeal expired. Thus, if a later appellate decision effects a change in the law, and if that change is only applicable to cases that were on direct appeal when that decision was issued, the pertinent question is whether the defendant’s original time for filingan appeal had expired when the new decision was issued. This rule of retroactivity is not altered by the fact that the defendant later pursues a collateral attack and is granted the remedy of pursuing a late appeal. Accordingly, we conclude that Sakar is not entitled to retroactive application of Blakely.
Read the full opinion on CourtListener → -
The court held that correcting the offender score did not reopen an otherwise final exceptional sentence to a Blakely jury-finding challenge.
State Of Washington, V. Dale Robertson Mitchell · Washington Court of Appeals, Division One (unpublished) · filed
Thus, even if Judge McDonald had been explicit that he was exercising discretion and independently imposing the 300-month exceptional sentence (which will be discussed below), that still would not have implicated Blakely because the change in the offender score did not disturb the validity of the exceptional sentence.
Read the full opinion on CourtListener →
Does this case still carry your argument?
Describe your facts. Ezel reads Blakely v. Washington and the cases that treated it, then tells you whether it still holds for your situation, with citations.
Opens in Ezel Pro.
- Checks the law as it stands today, not only this page
- Cites every source it relies on, so you can verify it
- Chat, drafting and research in one workspace