Sixth Amendment, Ring v. Arizona
       |           

Welcome, Guest. Please login or register.
Did you miss your activation email?
April 29, 2024, 01:47:58 PM
News: Election Simulator 2.0 Released. Senate/Gubernatorial maps, proportional electoral votes, and more - Read more

  Talk Elections
  General Discussion
  Constitution and Law (Moderator: Okay, maybe Mike Johnson is a competent parliamentarian.)
  Sixth Amendment, Ring v. Arizona
« previous next »
Pages: [1]
Poll
Question: The holding was...
#1
Constitutionally sound
 
#2
Constitutionally unsound
 
Show Pie Chart
Partisan results

Total Voters: 3

Author Topic: Sixth Amendment, Ring v. Arizona  (Read 1649 times)
A18
Atlas Star
*****
Posts: 23,794
Political Matrix
E: 9.23, S: -6.35

Show only this user's posts in this thread
« on: February 03, 2006, 12:26:13 PM »

Ring v. Arizona, 536 U.S. 584 (2002)

At petitioner Ring's Arizona trial for murder and related offenses, 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, the statutory maximum penalty for first-degree murder, unless further findings were made by a judge conducting a separate sentencing hearing. The judge at that stage must determine the existence or nonexistence of statutorily enumerated "aggravating circumstances" and any "mitigating circumstances." The death sentence may be imposed only if the judge finds at least one aggravating circumstance and no mitigating circumstances sufficiently substantial to call for leniency. Following such a hearing, Ring's trial judge sentenced him to death. Because the jury had convicted Ring of felony murder, not premeditated murder, Ring would be eligible for the death penalty only if he was, inter alia, the victim's actual killer. See Enmund v. Florida, 458 U. S. 782. 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, 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.

On appeal, Ring argued that Arizona's capital sentencing scheme violates the Sixth Amendment's jury trial guarantee by entrusting to a judge the finding of a fact raising the defendant's maximum penalty. See Jones v. United States, 526 U. S. 227; Apprendi v. New Jersey, 530 U. S. 466. The State responded that this Court had upheld Arizona's system in Walton v. Arizona, 497 U. S. 639, 649, and had stated in Apprendi that Walton remained good law. The Arizona Supreme Court observed that Apprendi and Jones cast doubt on Walton's continued viability and found that the Apprendi majority's interpretation of Arizona law, 530 U. S., at 496-497, was wanting. Justice O'Connor's Apprendi dissent, id., at 538, the Arizona court noted, correctly described how capital sentencing works in that State: A defendant cannot receive a death sentence unless the judge makes the factual determination that a statutory aggravating factor exists. Nevertheless, recognizing that it was bound by the Supremacy Clause to apply Walton, a decision this Court had not overruled, the Arizona court rejected Ring's constitutional attack. It then upheld the trial court's finding on the pecuniary gain aggravating factor, reweighed that factor against Ring's lack of a serious criminal record, and affirmed the death sentence.

Held: Walton and Apprendi are irreconcilable; this Court's Sixth Amendment jurisprudence cannot be home to both. Accordingly, Walton is overruled to the extent that it allows a sentencing judge, sitting without a jury, to find an aggravating circumstance necessary for imposition of the death penalty. See 497 U. S., at 647-649. Because Arizona's enumerated aggravating factors operate as "the functional equivalent of an element of a greater offense," Apprendi, 530 U. S., at 494, n. 19, the Sixth Amendment requires that they be found by a jury.
Logged
Emsworth
Junior Chimp
*****
Posts: 9,054


Show only this user's posts in this thread
« Reply #1 on: February 03, 2006, 05:01:56 PM »

Sound decision. All elements of an offense must be proven to a jury, not just some of them.
Logged
Pages: [1]  
« previous next »
Jump to:  


Login with username, password and session length

Terms of Service - DMCA Agent and Policy - Privacy Policy and Cookies

Powered by SMF 1.1.21 | SMF © 2015, Simple Machines

Page created in 0.024 seconds with 13 queries.