Ring v. Arizona - 536 U.S. 584, 122 S. Ct. 2428 (2002)

Rule:

The United States Supreme Court overrules Walton v. Arizona, 497 U.S. 639, 111 L. Ed. 2d 511 (1990), to the extent that it allows a sentencing judge, sitting without a jury, to find an aggravating circumstance necessary for imposition of the death penalty.

Facts:

In Walton v Arizona (1990) 497 US 639, 111 L Ed 2d 511, 110 S Ct 3047, the United States Supreme Court held, among other matters, that Arizona's capital sentencing scheme--which allowed a trial judge sitting alone, after a jury had convicted a defendant of first-degree murder, to determine the presence of aggravating factors required by state law for imposition of the death penalty--was compatible with the Federal Constitution's Sixth Amendment because the additional facts found by the judge were merely sentencing factors and not elements of the offense of capital murder. Subsequently, in Apprendi v New Jersey (2000) 530 US 466, 147 L Ed 2d 435, 120 S Ct 2348, a noncapital case, the Supreme Court held, among other matters, that the Sixth Amendment did not permit defendants to receive a penalty greater than they could receive under the facts reflected in a jury's verdict, even if a judge's additional findings were characterized as sentencing factors.

At petitioner Ring's Arizona trial for murder and related offenses, the jury deadlocked on premeditated murder, but found Ring guilty of felony murder occurring in the course of armed robbery. Under Arizona law, Ring could not be sentenced to death, the statutory maximum penalty for first-degree murder, unless further findings were made by a judge conducting a separate sentencing hearing. The judge at that stage must determine the existence or nonexistence of statutorily enumerated "aggravating circumstances" and any "mitigating circumstances." The death sentence may be imposed only if the judge finds at least one aggravating circumstance and no mitigating circumstances sufficiently substantial to call for leniency. Following such a hearing, Ring's trial judge sentenced him to death. Because the jury had convicted Ring of felony murder, not premeditated murder, Ring would be eligible for the death penalty only if he was, inter alia, the victim's actual killer. Citing accomplice testimony at the sentencing hearing, the judge found that Ring was the killer. The judge then found two aggravating factors, one of them, that the offense was committed for pecuniary gain, as well as one mitigating factor, Ring's minimal criminal record, and ruled that the latter did not call for leniency.

Issue:

May an aggravating factor be found by the judge, as Arizona law specified?

Answer:

No

Conclusion:

The Court concluded that the Walton decision and the Apprendi rule were irreconcilable because there was no specific reason for excepting capital defendants from the constitutional protections extended to defendants generally. Because Arizona's enumerated aggravating factors operated as the functional equivalent of an element of a greater offense, the Sixth Amendment required that they be found by a jury. The Court overruled Walton to the extent that it allowed a sentencing judge, sitting without a jury, to find an aggravating circumstance necessary for imposition of the death penalty.