Ring v. Arizona

Background

Timothy Ring, convicted by a jury of felony murder in Arizona, faced a separate sentencing hearing where the trial judge alone found facts called "aggravating circumstances" and imposed the death penalty. Arizona law required the judge to make those factual findings before death could be imposed. The Arizona Supreme Court upheld that procedure, but recent precedents, especially Apprendi, raised doubt about Walton v. Arizona, which had allowed judge-only findings.

Reasoning

The Court addressed whether the jury-trial right (the Sixth Amendment guarantee of a jury) requires jurors to find any fact that increases a defendant's maximum punishment. The Justices held Apprendi's rule—that any fact increasing the maximum must be found by a jury beyond a reasonable doubt—governs capital cases as well. Because Arizona's law made the judge's findings necessary to impose death, Walton's contrary holding could not stand. The Court overruled Walton to the extent it allowed a judge, sitting alone, to find aggravating factors and reversed the Arizona Supreme Court's judgment.

Real world impact

States that let judges, rather than juries, find facts that make a defendant death-eligible must revise their procedures so juries decide those facts. The decision requires jury findings for aggravators, will affect capital sentencing in several States with judge-based systems, and sends the case back to lower courts for further proceedings. The ruling is final on the Sixth Amendment issue in this appeal but may lead to new challenges and changes in state sentencing rules.

Dissents or concurrances

Several Justices wrote separately. Justice Scalia (joined by Justice Thomas) concurred on the jury-finding principle. Justice Breyer concurred in the judgment based on the Eighth Amendment and jury sentencing. Justice O'Connor dissented, arguing Apprendi should be overruled instead.