Ring v. Arizona

PETITIONER: Ring
RESPONDENT: Arizona
LOCATION: United States District Court Eastern District of Michigan

DOCKET NO.: 01-488
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: Arizona Supreme Court

CITATION: 536 US 584 (2002)
ARGUED: Apr 22, 2002
DECIDED: Jun 24, 2002

ADVOCATES:
Andrew D. Hurwitz - Argued the cause for the petitioner
Janet Napolitano - Argued the cause for the respondent

Facts of the case

At Timothy Ring's trial for murder, 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, unless further findings were made by a judge conducting a separate sentencing hearing and only if the judge finds at least one aggravating circumstance and no mitigating circumstances sufficiently substantial to call for leniency. Because the jury had convicted Ring of felony murder, not premeditated murder, Ring would be eligible for the death penalty only if he was 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 being 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.

Question

Does Arizona's capital sentencing scheme violate the Sixth Amendment's jury trial guarantee by entrusting to a judge the finding of facts sufficient to impose the death penalty?

Media for Ring v. Arizona

Audio Transcription for Opinion Announcement - June 24, 2002 in Ring v. Arizona

William H. Rehnquist:

The opinion of the Court in No. 01-488 Ring against Arizona will be announced by Justice Ginsburg.

Ruth Bader Ginsburg:

It has been said that most legal controversies turn on two questions: who decides, and where do you draw the line?

This case presents the question of who decides, judge or jury?

The context is capital murder, the issue, life or death.

An Arizona jury found Timothy Ring guilty of first degree murder.

Then the trial judge seating without a jury conducted a sentencing hearing.

Under Arizona law, to impose death rather than life-imprisoned the sentencing judge must find at least one of several statutorily enumerated aggravating circumstance, for example, that the murder was committed in an unusually cruel manner or for financial gain.

In Ring’s case, a murder committed in the course of robbery, the judge found the latter aggravating factor and also no overweighing cause for leniency and so sentenced Ring to death.

Ring maintains that the right to trial by jury guaranteed by the Sixth Amendment to the constitution precludes assignment of the aggravating factor determination to a judge.

Any finding necessary to increase a sentence above the maximum, otherwise, applicable here to raise the sentence from life to death, Ring contends falls within the decisional providence of the jury.

We rejected that very argument in a 1990 decision Walton against Arizona.

In Walton, we held that Arizona property assign the aggravating factor determination to the judge.

Aggravating factors, we said, were sentencing considerations not elements of the offensive capital murder therefore, they prompted no jury trial right.

Two years ago, ten years after Walton, we decided a pack mocking case of Apprendi V. New Jersey.

Apprendi held that the Sixth Amendment prohibits exposing a defendant to a prison term longer than the maximum sentence he could receive based solely on the facts resolved by the jury’s verdict.

The Apprendi majority did not overrule Walton, instead the court distinguished Walton from Apprendi on the ground that under Arizona’s capital sentencing scheme, juries did bear responsibility for finding all facts necessary to put a crime in the capital category.

The dissenters in Apprendi thought the majority had missperceived Arizona law.

A defendant convicted of first degree murder in Arizona, the Apprendi dissenters observed, cannot receive a death sentence unless a judge makes the factual determination that a statutory aggravating factor exists.

This reality, that Apprendi dissenters said, made it impossible to reconcile the two decisions.

The dissenters in Apprendi of course thought Walton was the precedent to preserve and Apprendi misguided.

When Timothy Ring appealed his death sentence to the Arizona Supreme Court, that Court agreed with him that Apprendi cast out on Walton’s continued viability.

Politely, that Court explained that the Aprendi majority’s attempt to distinguish Walton was unsatisfying.

A defendant convicted of first degree murder in Arizona that State Highest Court said cannot receive a death sentence unless a judge makes the factual determination that the statutory aggravating factor exists.

Without that critical finding, the maximum sentence to which the defendant exposed its life imprisonment and not the death penalty.

The Arizona Supreme Court understood however, that it was bound to follow Walton unless and until this Court overruled it, accordingly, that Court rejected Ring’s Sixth Amendment argument and affirmed his death sentence.

Informed by the Arizona Supreme Court’s account of Arizona law, we now comprehend, as the Apprendi dissenters did two years ago, that Apprendi and Walton are indeed irreconcilable and we today, overrule Walton.

We hold that the Sixth Amendment secures the capital defendant no less than to non-capital defendant the right to a jury determination of any fact on which the legislature conditions an increase in their maximum punishment.

Resisting the conclusion, we announce today the State of Arizona essentially restated the Apprendi majority’s portrayal of Alabama law.

Ring was convicted of first degree murder for which Arizona law specifies death or life imprisonment as the only sentencing options.

Ring was therefore sentenced within the range of punishment authorized by the jury’s guilty verdict.