Ring v. Arizona
122 S Ct 2428 (2002)
Facts of the case:
On November 28, 1994, The body of an armored van driver was found dead inside the vehicle. Also, there was more than $800,000 missing from the van leading police to believe that this was a robbery and homicide case. There were no witnesses to the crime except a local bystander who stated that two vehicles, a van and a red truck were speeding down the road earlier that day and had neglected to stop at the intersection where there is a stop sign posted.
Based on a tip, police were able to locate the red pickup truck and it's owner, Timothy Ring. Police then listened to Timothy Ring's phone conversations and quickly learned that he was involved with both the robbery and shooting. In the following days, police obtained a warrant and conducted a search of Timothy Ring's home. They discovered a rifle and a bag full of cash in the amount of $271,681. They also recovered a letter with $575,995 written on the inside. This amount, when added to the amount of cash recovered, added up to the same amount that had been stolen from the armored van.
A jury found Ring guilty of "murder occurring during an armed robbery". This decision was based on the evidence obtained by the police. In Arizona, this is a capital offence. The prosecution's case had no evidence that identified Ring as the "shooter". However, under Arizona law at that time, a judge alone was required to determine the presence or absence of aggravating factors for imposition of the death penalty.
During the sentencing phase, the judge heard testimony from one of Ring's accomplices who placed all the blame on Ring. He said that Ring had not only planned out the robbery, but he was also the one who had shot the driver of the armored van. The judge then found beyond a reasonable doubt the aggravating factor needed to sentence Ring to death. The judge found that the crime was committed for money and "in an especially heinous, cruel or depraved manner." The judge then sentenced Ring to the death penalty.
Upon automatic appeal, the Arizona Supreme Court affirmed the sentence. The case was then appealed to the US Supreme Court.
Issue before the US Supreme Court:
As to the right to a jury trial under the sixth amendment, as made applicable to the states through the fourteenth amendment, may a judge alone determine aggravating factors necessary to impose a death sentence?
Capital defendants, no less than noncapital defendants, are entitled to a jury determination of any fact on which the legislature conditions an increase in their maximum punishment.
The US Supreme Court's Decision:
The Supreme Court decided that juries rather than judges must make the determinations that subject a convicted murder to the death penalty. This was decided on a 7 to 2 decision.
Justice Ginsburg explained the decision for the Ring case. She stated that it is unusual for the court not to follow its past decisions.
"But the doctrine is not unyielding: we have overturned prior decisions when there is strong reason for setting the law straight. This is such a case," she said.
The Apprendi decision dictated its application to the death sentence context, stating:
"The right to trial by jury guaranteed by the Sixth Amendment would be senselessly diminished if it encompassed the fact-finding necessary to increase a defendant's sentence by two years, but not the fact-finding necessary to put him to death".
Justice Ginsburg concluded that the Sixth Amendment applies to both.
This case set forth the precedent that juries, not the judge, will have the ability to exercise their discretion when deciding aggravating factors which could lead to the enforcement of the death penalty.
This decision is also significant because it invalidated death penalty laws of five states and cast doubt on the laws of four others.
It also overturned the 1990 U. S. Supreme...
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