McKinney v. Arizona

Background

A man convicted of two 1991 murders was sentenced to death by an Arizona trial judge and the Arizona Supreme Court affirmed in 1996. Years later, a federal appeals court said Arizona courts had failed to consider his post‑traumatic stress disorder (PTSD) as mitigating evidence. The State asked the Arizona Supreme Court to reweigh the aggravating and mitigating factors; that court reviewed the record, considered the PTSD evidence, and again upheld the two death sentences in 2018. The defendant then asked this Court to decide whether the reweighing was lawful.

Reasoning

The key question was whether a state high court may itself reweigh aggravating and mitigating evidence on collateral review, or whether a jury must resentence the defendant. The Court relied on prior decisions saying appellate courts may reweigh evidence (Clemons) and explained that later cases requiring jury findings of aggravating facts (Ring and Hurst) do not force a jury to do the final weighing. Ring and Hurst require juries to find the facts that make a defendant death‑eligible, but they do not require jury weighing on collateral review and do not apply retroactively here. The Court therefore held that the Arizona Supreme Court permissibly reweighed the evidence on collateral review and affirmed the state court’s decision.

Real world impact

State supreme courts may, under their own law, reweigh aggravating and mitigating evidence to address certain constitutional sentencing errors. That means defendants in similar situations will not automatically get a new jury resentencing when a state court conducts a lawful appellate reweighing. The ruling does not eliminate the need for jury findings of aggravating facts on direct review under Ring and Hurst.

Dissents or concurrances

The dissent argued the 2018 reweighing was effectively a renewed direct review, so Ring should apply and the death sentences should be invalidated, a view the Court rejected.