Ring v. Arizona
536 U.S. 584 (2002)
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Rule of Law:
The Sixth Amendment requires that a jury, not a judge, must find any aggravating fact that is necessary for the imposition of the death penalty.
Facts:
- On November 28, 1994, an armored van was robbed outside a Dillard's department store in Glendale, Arizona.
- The van's driver, John Magoch, was found dead inside the vehicle from a single gunshot wound.
- More than $562,000 in cash and $271,000 in checks were stolen from the van.
- An informant's tip led police to investigate Timothy Ring and his friend, James Greenham, for the robbery and murder.
- Police wiretaps recorded Ring making incriminating statements, and a later search of his house uncovered a duffel bag containing over $271,000 in cash.
- At trial, Ring testified that the money was startup capital for a business he was forming and that he had earned it legitimately as an FBI informant and gunsmith.
- The prosecution presented evidence contradicting Ring's claims, showing he had been paid only $458 by the FBI and had earned very little as a bail bondsman.
Procedural Posture:
- Timothy Ring was tried for first-degree murder and other charges in an Arizona state trial court.
- The jury convicted Ring of felony murder but deadlocked on the charge of premeditated murder.
- Pursuant to Arizona law, a separate sentencing hearing was conducted before the trial judge, sitting alone.
- At the hearing, Ring's accomplice, James Greenham, testified that Ring was the shooter.
- The trial judge found two statutory aggravating factors: that the murder was committed for pecuniary gain and in an especially heinous, cruel, or depraved manner.
- Based on these findings, the trial judge sentenced Ring to death.
- Ring (appellant) appealed to the Arizona Supreme Court, arguing the sentencing scheme violated the Sixth Amendment.
- The Arizona Supreme Court (appellee was the State of Arizona) affirmed the death sentence, concluding it was bound by the U.S. Supreme Court's precedent in Walton v. Arizona, despite its tension with the more recent Apprendi v. New Jersey decision.
- The U.S. Supreme Court granted Ring's petition for a writ of certiorari.
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Issue:
Does Arizona's capital sentencing scheme, which allows a trial judge, sitting alone, to determine the presence of aggravating factors required for the imposition of the death penalty, violate the Sixth Amendment right to a jury trial?
Opinions:
Majority - Justice Ginsburg
Yes. Arizona's capital sentencing scheme violates the Sixth Amendment right to a jury trial because it entrusts to a judge the finding of facts necessary to impose the death penalty. Capital defendants are entitled to a jury determination of any fact, other than the fact of a prior conviction, that increases their maximum punishment. In Arizona, the maximum sentence for first-degree murder based on a jury's verdict alone is life imprisonment; only after a judge finds an aggravating circumstance can the death penalty be imposed. Therefore, such aggravating factors operate as the 'functional equivalent of an element of a greater offense' and must be found by a jury beyond a reasonable doubt. This decision overrules Walton v. Arizona, as its holding is irreconcilable with the principles established in Apprendi v. New Jersey.
Concurring - Justice Scalia
Yes. While the requirement for states to find 'aggravating factors' originated from the Court's wrongly-decided Eighth Amendment jurisprudence, the Sixth Amendment's jury-trial guarantee is fundamental and must be applied consistently. All facts essential to the imposition of a specific level of punishment, regardless of what they are called, must be found by a jury beyond a reasonable doubt. Allowing a judge to make the factual findings that lead to a death sentence erodes the people's traditional belief in the right to a trial by jury and must be rejected.
Concurring - Justice Kennedy
Yes. Although I continue to believe Apprendi v. New Jersey was wrongly decided, it is now the law and its holding must be implemented in a principled way. There is no principled way to reconcile Apprendi with Walton v. Arizona. In Arizona, the judge's finding of an aggravating circumstance indisputably exposes the defendant to a greater punishment than that authorized by the jury's guilty verdict alone, which is precisely what Apprendi forbids.
Concurring - Justice Breyer
Yes. I concur only in the judgment, not the reasoning. Instead of the Sixth Amendment, I believe the Eighth Amendment's prohibition on cruel and unusual punishment mandates that a jury, not a judge, must make the decision to sentence a defendant to death. Juries possess a comparative advantage over judges in expressing the 'conscience of the community on the ultimate question of life or death,' which is critical for determining if the retributive purpose of capital punishment is served in a particular case.
Dissenting - Justice O'Connor
No. The Court's prior decision in Apprendi was a serious mistake that was not required by the Constitution or precedent, and it should be overruled, not extended. Apprendi has had a severely destabilizing effect on the criminal justice system by unleashing a flood of petitions and appeals. Rather than overrule Walton, which was correctly decided, the Court should have overruled Apprendi. Today's decision exacerbates the harm by invalidating the capital sentencing schemes of five states and casting doubt upon others.
Analysis:
Ring v. Arizona is a landmark Sixth Amendment case that extended the rule of Apprendi v. New Jersey to capital sentencing schemes. The decision fundamentally altered capital punishment procedures by requiring that juries, not judges, find the aggravating factors that make a defendant eligible for the death penalty. This ruling invalidated the judicial fact-finding systems in several states, forcing legislatures to rewrite their death penalty statutes to comply with the Sixth Amendment. The case solidified the principle that any fact that increases a defendant's maximum possible sentence is the functional equivalent of an element of the crime and must be proven to a jury beyond a reasonable doubt.
