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

Jan 31, 2017 | 0 comments

Jan 31, 2017 | Essays | 0 comments

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Ring v. Arizona, 536 U.S. 584 (2002)

Facts

At the murder trial of Timothy Ring, the jury was deadlocked on the premeditated murder. However, the found the accused, Ring, to be guilty of felony murder that occurred during the time of armed robbery. Ring, under the law of Arizona could be handed a death sentence, unless additional findings by a judge conducting sentencing hearing that is separate were made, and only at least one circumstance that is aggravating is found by the judge, and no sufficiently mitigating circumstances that is substantial and can lead to a call for leniency. Because Ring had been convicted of felony murder by the jury and not the premeditated murder, this means that eligibility of Ring  for death penalty was high if actually  he was the killer of the victim. During the hearing of the sentence, the judge cited the testimony of the accomplice, and found ring to be the killer. Moreover, the judge found two additional aggravating factors to the case. The first one being that commitment of the offence was done for pecuniary gain, besides another mitigating factor, of the minimal criminal record of ring. In the ruling, the judge ruled that Ring did not deserve to be given leniency.

Legal question

Does the capital sentencing scheme of Arizona violates the jury’s Sixth Amendment trial guarantee, by solely entrusting the finding of facts to a judge that are sufficient to lead to death penalty sentencing

Courts ruling

There were seven votes for, and two votes against. The decision of the majority was delivered by Justice Ginsburge and concurred by Breyen, Thomas, Kennedy and Scalia. The dissenting voices were from Rehnquist and O’Connor.

The courts rationale

The legal provision to the courts gives the jury the right to trial. In the seven verses two opinion of the jury delivered by Justice Ginsburg Bader Ruth, it was held by the courts that because it is specified by Arizona that the aggravating factors operate as “useful equivalent of a greater offence element,” the Sixth Amendment stipulates that they be identified by the jury.  For instance, under Apprendi verses New Jersey, 530 U.S.446, where the court maintained that the Sixth Amendment does not, in any case permit a defendant to be “rendered to a penalty that exceeds the maximum he would be sentenced if punished in accordance to the reflected facts in the verdict of the jury alone.” Moreover, the court in its capacity overruled the case of Walton  verses Arizona, 497 U.S. 639, so far it permits the judge, sitting without jury and  delivering sentence, to find the necessary aggravating circumstance for the death penalty imposition.

Concurring

Justice Ginsburg wrote that the guaranteed right to trial by the jury by the Sixth Amendment  would be diminished senselessly if it included the necessary fact finding to increase the sentence of the defendant by two years, but not the necessary fact finding to put him to death.

 Dissent

Dissenting Justice O’Conner made an argument that Apprendi was a decision full or errors and other than Walton, it should be overruled. She further made her argument that the decision of the courts would have very serious consequences, by opening up litigation flood from the death row inmates. This would create uncertainty in the laws of the other nine states that adopted either partial or total judicial finding of facts in death sentences. 

References

Constitutional Law-Judge’s Imposition of Death Penalty Violates Sixth Amendment’s Right to a Trial by Jury-Ring v. Arizona, 536 U.S. 584 (2002). (January 01, 2004). Suffolk University Law Review, 37, 247-253.

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