Ring v. Arizona

The State of Arizona (plaintiff) prosecuted Timothy Ring (defendant) for murder, a crime for which the penalty was either life imprisonment or death. The jury convicted Ring. Arizona's sentencing statute provided that a death penalty could be imposed only if the trial judge found aggravating factors in the case. The judge found such factors and sentenced Ring to death. Ring appealed, and the Arizona Supreme Court affirmed Ring's death sentence. The United States Supreme Court granted certiorari to consider whether two relevant Sixth Amendment cases, Walton v. Arizona, 497 U.S. 639 (1990), and Apprendi v. New Jersey, 530 U.S. 466 (2000), were compatible. Walton held that, so long as the jury was the factfinder as to the defendant's guilt, the judge could be the factfinder as to aggravating-sentencing factors. Apprendi held that a jury must be the factfinder if the aggravating factors increase the defendant's penalty beyond the sentencing range for his underlying offense. Arizona argued that: (1) Apprendi did not control Ring's case because the death penalty was within the sentencing range for murder, and Walton permitted the judge to determine the existence of aggravating factors; (2) Arizona's sentencing law was a permissible way for the state to comply with Eighth Amendment requirements; and (3) it is fairer and more efficient for judges than juries to determine the existence of aggravating factors.