Ring v. Arizona
Encyclopedia
Ring v. Arizona, , is a case in which the United States Supreme Court
applied the rule of Apprendi v. New Jersey
, , 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
, , that had previously rejected this contention. It also essentially overruled the provisions of Spaziano v. Florida
which allowed a judge to impose a death sentence, overriding a jury's recommendation of life imprisonment.
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
, , 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
, , 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
. At oral argument, Andrew D. Hurwitz
argued for the petitioners and Arizona Attorney General Janet Napolitano
argued for the State of Arizona.
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
, , 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 Apprendis general rule.
Noting the disparity between Justice Breyer
's continued rejection of Apprendi and concurrence in Ring, Justice Scalia
added:
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.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
applied the rule of Apprendi v. New Jersey
Apprendi v. New Jersey
Apprendi v. New Jersey , , was a United States Supreme Court decision. The Court ruled that the Sixth Amendment right to a jury trial, incorporated against the states through the Fourteenth Amendment, prohibited judges from enhancing criminal sentences beyond statutory maximums based on facts...
, , to capital sentencing schemes, holding that the Sixth Amendment
Sixth Amendment to the United States Constitution
The Sixth Amendment to the United States Constitution is the part of the United States Bill of Rights which sets forth rights related to criminal prosecutions...
requires a jury to find the aggravating factors necessary for imposing the death penalty. Ring overruled a portion of Walton v. Arizona
Walton v. Arizona
Walton v. Arizona, 497 U.S. 639 , upheld two important aspects of the capital sentencing scheme in the U.S. state of Arizona — judicial sentencing and the aggravating factor "especially heinous, cruel, or depraved" — as not unconstitutionally vague. The Supreme Court has overruled the first of...
, , that had previously rejected this contention. It also essentially overruled the provisions of Spaziano v. Florida
Spaziano v. Florida
Spaziano v. Florida, was two United States Supreme Court cases dealing with the imposition of the death penalty. In the first case, 454 U.S. 1037, , the Supreme Court, with two dissents, refused Spaziano's petition for certiorari...
which allowed a judge to impose a death sentence, overriding a jury's recommendation of life imprisonment.
Facts of the case
On November 28, 1994, an armored carArmored car (valuables)
A common meaning of armored car is as an armored van or truck, used in transporting valuables, such as large quantities of money . The armored car is a multifunctional vehicle designed to protect and ensure the well being of the transported individuals and/or contents...
parked in front of Arrowhead Mall in Glendale, Arizona
Glendale, Arizona
Glendale is a city in Maricopa County, Arizona, USA, located about nine miles northwest from Downtown Phoenix. According to 2010 Census Bureau, the population of the city is 226,721....
, 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
Sun City, Arizona
Sun City is a census-designated place and unincorporated town in Maricopa County, Arizona, United States. The population was 38,309 at the 2000 census...
, 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
Felony murder
The rule of felony murder is a legal doctrine in some common law jurisdictions that broadens the crime of murder in two ways. First, when an offender kills accidentally or without specific intent to kill in the course of an applicable felony, what might have been manslaughter is escalated to 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
Arizona Supreme Court
The Arizona Supreme Court is the state supreme court of the U.S. state of Arizona. It consists of a Chief Justice, a Vice Chief Justice, and three associate justices. Each justice is appointed by the governor of Arizona from a list recommended by a bipartisan commission. Justices stand for...
, Apprendi v. New Jersey
Apprendi v. New Jersey
Apprendi v. New Jersey , , was a United States Supreme Court decision. The Court ruled that the Sixth Amendment right to a jury trial, incorporated against the states through the Fourteenth Amendment, prohibited judges from enhancing criminal sentences beyond statutory maximums based on facts...
, , 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
Walton v. Arizona
Walton v. Arizona, 497 U.S. 639 , upheld two important aspects of the capital sentencing scheme in the U.S. state of Arizona — judicial sentencing and the aggravating factor "especially heinous, cruel, or depraved" — as not unconstitutionally vague. The Supreme Court has overruled the first of...
, , 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
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
. At oral argument, Andrew D. Hurwitz
Andrew D. Hurwitz
Andrew D. Hurwitz is a Phoenix, Arizona attorney currently serving as Vice Chief Justice of the Arizona Supreme Court. He also has been nominated to serve as a judge on the United States Court of Appeals for the Ninth Circuit. He is a native of Boonton, New Jersey and a graduate of Boonton High...
argued for the petitioners and Arizona Attorney General Janet Napolitano
Janet Napolitano
Janet Napolitano is the third and current United States Secretary of Homeland Security, serving in the administration of President Barack Obama. She is the fourth person to hold the position, which was created after the 9/11 terrorist attacks. A member of the Democratic Party, she was the 21st...
argued for the State of Arizona.
Apprendi applies to capital sentencing schemes
Writing for the majority, Justice GinsburgRuth Bader Ginsburg
Ruth Joan Bader Ginsburg is an Associate Justice of the Supreme Court of the United States. Ginsburg was appointed by President Bill Clinton and took the oath of office on August 10, 1993. She is the second female justice and the first Jewish female justice.She is generally viewed as belonging to...
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
Jones v. United States
-Facts:Jones and two accomplices, Oliver and McMillan, held up two men, Mutanna and Mardaie. Jones and McMillan took the victims' money. Oliver beat Mutanna with a gun. Olver and McMillan left the scene in Jones's car, while Jones forced Mardaie into Mutanna's car and drove off in it. Jones...
, , 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 Apprendis general rule.
Noting the disparity between Justice Breyer
Stephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
's continued rejection of Apprendi and concurrence in Ring, Justice Scalia
Antonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
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
Stephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
argued that jury sentencing in capital cases was required by the Eighth Amendment
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
. 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
Sandra Day O'Connor
Sandra Day O'Connor is an American jurist who was the first female member of the Supreme Court of the United States. She served as an Associate Justice from 1981 until her retirement from the Court in 2006. O'Connor was appointed by President Ronald Reagan in 1981...
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.