Walton v. Arizona - 497 U.S. 639, 110 S. Ct. 3047 (1990)

Rule:

So long as a State's method of allocating the burdens of proof does not lessen the State's burden to prove every element of the offense charged, or to prove the existence of aggravating circumstances, a defendant's constitutional rights are not violated by placing on him the burden of proving mitigating circumstances sufficiently substantial to call for leniency.

Facts:

Petitioner Walton was found guilty in an Arizona court of first-degree murder and was sentenced in a separate sentencing hearing before the judge, as required by state law. Under that law, the judge, inter alia, would determine the existence of aggravating and mitigating circumstances. The state law further stipulated that the judge "shall impose" a death sentence if he found one or more of several enumerated aggravating circumstances, and no mitigating circumstances sufficiently substantial to call for leniency. The burden was on the prosecution to establish the existence of aggravating circumstances and on the defendant to establish mitigating ones. The judge sentenced Walton to death, after finding the presence of two aggravating circumstances - that the murder was committed "in an especially heinous, cruel or depraved manner," and that it was committed for pecuniary gain - and that, considering all of the mitigating factors urged by Walton, the mitigating circumstances did not call for leniency. The State Supreme Court upheld the sentence. Petitioner sought certiorari review, contending that his death sentence was invalid and unconstitutional.

Issue:

Did the Arizona capital sentencing scheme violate the Constitution, thereby making petitioner’s death sentence invalid?

Answer:

No.

Conclusion:

The Court affirmed petitioner’s death sentence, holding that the Arizona capital sentencing scheme did not violate U.S. Const. amend. VI because it was not required that a jury impose the sentence of death or make the findings prerequisite to imposition of such sentence, and aggravating circumstances were not separate penalties or offenses. The sentencing scheme did not violate U.S. Const. amends. VIII and XIV in allocating the burden of establishing mitigating circumstances to petitioner because the method of allocating the burden of proof did not lessen the state's burden of proving every element of the charged offense.