Ring v. Arizona

Supreme Court of the United States · 2002 · Criminal Law

Criminal LawSixth AmendmentCapital PunishmentJury TrialSixth Amendmentjury trialcapital sentencingaggravating factors

Facts

Arizona law provided that after a jury found a defendant guilty of first-degree murder, the trial judge alone would conduct a sentencing hearing and determine whether statutory aggravating circumstances existed. Ring's jury convicted him of felony murder, but under Arizona law he could not receive death unless at least one aggravating factor was found beyond a reasonable doubt. At sentencing, the judge found that Ring was the killer or a major participant with reckless indifference and found aggravating circumstances including pecuniary gain, then imposed death. The Arizona Supreme Court recognized that Ring's death sentence required judicial factfinding but upheld the sentence under Walton.

Issue

When a jury's verdict alone authorizes only life imprisonment, may a judge rather than a jury find the aggravating circumstance necessary to make a defendant eligible for the death penalty? More broadly, does the Sixth Amendment require a jury to determine capital aggravating facts that increase the maximum authorized punishment?

Rule

Capital defendants, no less than noncapital defendants, are entitled under the Sixth Amendment to a jury determination of any fact on which the legislature conditions an increase in the maximum punishment. An aggravating circumstance necessary for imposition of the death penalty is the functional equivalent of an element of a greater offense and therefore must be found by a jury beyond a reasonable doubt.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, a jury convicts Darren Cole of first-degree murder. Under state law, the judge must impose life imprisonment unless the judge separately finds at least one statutory aggravating circumstance beyond a reasonable doubt, after which death becomes available.

If Darren argues that the sentencing scheme violates the Sixth Amendment, what is the best answer?

Explanation. The controlling rule is that any fact on which the legislature conditions an increase in the maximum punishment must be found by a jury beyond a reasonable doubt. If the jury verdict alone authorizes only life imprisonment, a judge cannot supply the aggravating fact that makes death available. Labels such as 'sentencing factor' do not control; effect does.