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Supreme Court· 6/24/2002

Ring v. Arizona

Citations

  • 536 U.S. 584
  • 122 S. Ct. 2428
  • 153 L. Ed. 2d 556
  • 2002 U.S. LEXIS 4651

About this case

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From Wikipedia, the free encyclopedia

2002 United States Supreme Court case

Ring v. Arizona, 536 U.S. 584 (2002), was a case in which the United States Supreme Court applied the rule of _Apprendi v. New Jersey _[1] to capital sentencing schemes, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty.[2] Ring overruled a portion of _Walton v. Arizona _,[3] which had rejected that contention.

The case was argued by then-Attorney General Janet Napolitano and future judge Andrew Hurwitz .

Facts of the case

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On November 28, 1994, an armored car parked in front of Arrowhead Mall in Glendale, Arizona , was robbed. The driver, John Magoch, was shot in the head as he opened the door to smoke, and died almost instantly. 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 felony murder under Arizona law.

The jury eventually convicted Ring of felony murder, but Ring could not be sentenced to death without further findings, and Arizona law provided that the judge alone would make the 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 it did not outweigh the aggravating factors and sentenced Ring to death. Ring's accomplices William Ferguson and James Greenham were sentenced to 16 and 27 years respectively for their roles in the crime.[4]

Apprendi applies to capital sentencing schemes

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Writing for the majority, Justice Ginsburg 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. To satisfy the jury-trial requirement of the Sixth Amendment as interpreted by Apprendi, additional factfinding was required. However, in Walton, the Court had expressly held that Arizona's capital sentencing scheme was not subject to such a requirement.

That 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. However, after Apprendi, which built on _Jones v. United States _, 526 U.S. 227 (1999), 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 Court said that the Sixth Amendment required a jury to find it. The Court found no principled basis for exempting capital cases from _Apprendi'_s general rule.

Noting the disparity between Justice Breyer 's continued rejection of Apprendi and concurrence in Ring, Justice Antonin Scalia 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.

Justice Sandra Day 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.

See also

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References

[(https://en.wikipedia.org/w/index.php?title=Ring_v._Arizona&action=edit&section=4 "Edit section: References")
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  1. ↑ _Apprendi v. New Jersey _, 530 U.S. 466 (2000).
  2. ↑ Ring v. Arizona, 536 U.S. 584 (2002).
  3. ↑ _Walton v. Arizona _, 497 U.S. 639 (1990).
  4. ↑ Jeffrey, Courtland (November 26, 2017). "Old Time Crime: Spending spree leads to arrests of armored car murder suspects in 1994" . KNXV-TV. Retrieved March 6, 2026.

External links

[(https://en.wikipedia.org/w/index.php?title=Ring_v._Arizona&action=edit&section=5 "Edit section: External links")
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United States Sixth Amendment case law

Impartial Jury Clause

Confrontation Clause

Assistance of Counsel Clause

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Editorial context from Wikipedia (CC-BY-SA 4.0).

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

  • holding that “a sentencing judge, sitting without a jury, [may not] find an aggravating circumstance necessary for imposition of the death penalty”
  • holding that the Fourteenth Amendment has not been construed to include the Fifth Amendment right to \presentment or indictment of a Grand Jury\
  • holding that, if the imposition of the death penalty depends on the existence of aggravating factors, a jury must find those factors beyond a reasonable doubt
  • holding that a jury, not a judge, must find facts necessary for imposition of the death penalty
  • holding that any fact essential to imposition of the death penalty must be submitted to a jury and found beyond a reasonable doubt
  • holding that a capital sentencing scheme under which a judge determines aggravating circumstances violates the Sixth Amendment right to a jury trial

Source: CourtListener parenthetical corpus (CC0).

Judges: Ginsburg, Stevens, Scalia, Kennedy, Souter, Thomas, Breyer, O'Connor, Rehnquist

Read full opinion on CourtListener

Cited by

3,065 cases in this archive cite this case; the 20 most cited are listed.

Cites

36 cases in this archive are cited by this case; the 20 most cited are listed.

Other cases named Ring v. Arizona

1 other CourtListener record shares this case name.

Sourced from CourtListener / Free Law Project (CC0).

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