Ring v. Arizona

SCOTUSCase
Litigants=Ring v. Arizona
ArgueDate=April 22
ArgueYear=2002
DecideDate=June 24
DecideYear=2002
FullName=Timothy Stuart Ring v. Arizona
USVol=536
USPage=584
Citation=122 S. Ct. 2428; 153 L. Ed. 2d 556; 2002 U.S. LEXIS 4651; 70 U.S.L.W. 4666; 2002 Cal. Daily Op. Service 5594; 2002 Daily Journal DAR 7047; 15 Fla. L. Weekly Fed. S 464
Prior=On writ of cert. to the Sup. Court of Arizona. "State v. Ring", 200 Ariz. 267
Subsequent=
Holding=Allowing sentencing judge, without jury, to find aggravating circumstance necessary for imposition of death penalty held to violate right to jury trial under Federal Constitution's Sixth Amendment..
SCOTUS=1994-2005
Majority=Ginsburg
JoinMajority=Stevens, Scalia, Kennedy, Souter, Thomas
Concurrence=Scalia
JoinConcurrence=Thomas
Concurrence2=Kennedy
Concurrence3=Breyer
Dissent=O'Connor
JoinDissent=Rehnquist
LawsApplied=U.S. Const. amend. VI

"Ring v. Arizona", ussc|536|584|2002, is a case in which the United States Supreme Court applied the rule of "Apprendi v. New Jersey", ussc|530|466|2000, to capital sentencing schemes, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty. "Ring" overruled a portion of "Walton v. Arizona", ussc|497|639|1990, that had previously rejected this contention.

Facts of the case

On November 28, 1994, an armored car parked in front of Arrowhead Mall in Glendale, Arizona, was robbed. The driver was shot in the head as he exited the van to smoke. One of the robbers then drove the van to a church in nearby Sun City, where they made off with $562,000 in cash and $271,000 in personal checks. An informant tipped the police off to Timothy Ring and two of his friends, who had recently made expensive purchases such as a new truck. Police eventually discovered that Ring was the ringleader of the operation. Ring was later charged with capital first-degree murder under Arizona law.

The jury eventually convicted Ring of first-degree murder under a felony murder theory. But Ring could not be sentenced to death without further findings, and Arizona law provided that the judge alone would make these findings. After a sentencing hearing, at which Ring's accomplices testified, the judge found that two aggravating factors applied: that Ring had committed the murder in expectation of pecuniary gain, and that he had committed the murder in an especially heinous, cruel, or depraved manner. Although he found that Ring had a "minimal" criminal record, the judge concluded that this did not outweigh the aggravating factors, and sentenced Ring to death.

By the time Ring's case was decided by the Arizona Supreme Court, "Apprendi v. New Jersey", ussc|530|466|2000, had been decided. In "Apprendi", the Court had held that any fact that increases the punishment for a crime above the statutory maximum punishment must be either submitted to a jury and proved beyond a reasonable doubt or admitted by the defendant. However, in "Walton v. Arizona", ussc|497|639|1990, the Court had explicitly ruled that the Sixth Amendment did not require jury finding of aggravating factors in Arizona's capital sentencing scheme. As the Arizona Supreme Court saw it, "Apprendi" undercut the holding of "Walton", yet "Walton" was directly controlling precedent from a higher court on a matter of federal constitutional law. The Arizona Court had no choice but to affirm Ring's conviction and death sentence. The U.S. Supreme Court granted Ring's petition for certiorari.

"Apprendi" applies to capital sentencing schemes

Writing for the majority, Justice Ginsburg began with an important characterization of Arizona's capital sentencing scheme. Based solely on the jury's verdict that Ring was guilty of first-degree murder, the greatest sentence for which Ring was eligible was life in prison. In order to satisfy the jury-trial requirement of the Sixth Amendment as interpreted by "Apprendi", additional factfinding was required. Yet in "Walton", the Court had expressly held that Arizona's capital sentencing scheme was not subject to such a requirement.

This characterization all but dictated the result. Prior decisions, including "Walton", had distinguished between the "elements" of a crime and "sentencing factors." The Sixth Amendment required a jury to find elements but allowed a judge to determine sentencing factors. Under "Walton", the aggravating factors were "sentencing factors" because they were the modern vehicle by which judges expressed their traditional sentencing discretion in capital cases. But after "Apprendi", which built on "Jones v. United States", ussc|526|227|1999, the relevant inquiry was "one not of form, but of effect." If a particular fact—whether it was called an "element" or a "sentencing factor"—exposed the defendant to a greater punishment, then the Sixth Amendment required a jury to find it. The Court found no principled basis for exempting capital cases from "Apprendi"'s general rule.

Noting the disparity between Justice Breyer's continued rejection of "Apprendi" and concurrence in "Ring", Justice Scalia added:

:While I am, as always, pleased to travel in Justice Breyer's company, the unfortunate fact is that today's judgment has nothing to do with jury sentencing. What today's decision says is that the jury must find the existence of the fact that an aggravating factor existed. Those States that leave the ultimate life-or-death decision to the judge may continue to do so — by requiring a prior jury finding of aggravating factor in the sentencing phase or, more simply, by placing the aggravating-factor determination (where it logically belongs anyway) in the guilt phase.

:There is really no way in which Justice Breyer can travel with the happy band that reaches today's result unless he says yes to Apprendi. Concisely put, Justice Breyer is on the wrong flight; he should either get off before the doors close, or buy a ticket to Apprendi-land.

Justice Breyer argued that jury sentencing in capital cases was required by the Eighth Amendment. At the same time he held to his position that jury factfinding of aggravating factors was not generally required in criminal cases. Because death is a different punishment, it must have additional procedural safeguards in order to ensure that it more accurately reflects both the moral judgment of the community and the blameworthiness of the individual defendant.

Justice O'Connor argued that the Court's decision would have serious consequences, opening up a flood of litigation from death-row inmates and creating uncertainty in the laws of nine other states that employed either total or partial judicial factfinding in death sentences.

ee also

* List of United States Supreme Court cases, volume 536

External links

*caselaw source
case="Ring v. Arizona", 536 U.S. 584 (2002)
enfacto=http://www.enfacto.com/case/U.S./536/584/
findlaw=http://caselaw.lp.findlaw.com/cgi-bin/getcase.pl?court=US&navby=case&vol=000&invol=01-488
other_source1=LII
other_url1=http://www.law.cornell.edu/supct/html/01-488.ZS.html
* [http://www.oyez.org/oyez/resource/case/1490/ Summary of case from OYEZ]