Ring v. Arizona

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536 U.S. 584 (2002), argued 22 Apr. 2002, decided 24 June 2002 by vote of 7 to 2; Ginsburg for the Court, Scalia, Kennedy, Thomas, and Breyer concurring, O’Connor and Rehnquist in dissent. The issue in Ring was whether Arizona's capital sentencing scheme violated the Sixth Amendment's jury trial guarantee.

Arizona's capital sentencing scheme, upheld by the Court in Walton v. Arizona (1990), specified that after a jury found a defendant guilty of first-degree murder, the trial judge alone determined the presence or absence of the aggravating circumstances required by Arizona law for the imposition of the death penalty. Then the defendant could be sentenced to death only if the judge found at least one aggravating circumstance and there were no mitigating circumstances substantial enough to call for mercy. The constitutionality of Arizona's sentencing system became unclear after the Court ruled in Apprendi v. New Jersey (2000) that the Sixth Amendment did not permit a defendant to be “expose[d] … to a penalty exceeding the maximum he would receive if punished according to the facts reflected in the jury verdict alone” (p. 483).

In Ring, the Court partially overruled Walton and determined that Arizona's sentencing scheme violated the Constitution to the extent that a judge's independent finding of an aggravating circumstance was necessary for the imposition of the death penalty. According to the Court, the Sixth Amendment required that any fact that increased the maximum penalty for a crime had to be submitted to a jury, for the presence of any such fact was effectively equivalent to an element of a greater offense. In a separate concurring opinion, Justice Stephen Breyer argued that jury sentencing in capital cases is simply mandated by the Eighth Amendment. Dissenting, Justice Sandra Day O’Connor argued that Apprendi was an erroneous decision and that it rather than Walton should be overruled.

Jennifer L. Culbert

Subjects: Law.

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