Walton v. Arizona

Jeffrey Walton (defendant) was found guilty of first-degree murder. In accordance with Arizona state law, the trial court rather than a jury determined whether Walton would be sentenced to death or to life imprisonment. State law also required that the trial court impose the death penalty if (1) one or more of several listed aggravating circumstances existed and (2) no mitigating circumstances were substantial enough to justify leniency. If the state proved that an aggravating circumstance existed, the burden was on the defendant to establish that sufficient mitigating circumstances existed to justify leniency. Possible aggravating circumstances included committing a murder for financial gain or “in an especially heinous, cruel or depraved manner.” Under state caselaw, “especially cruel” meant that the victim had suffered mental anguish before his death, and “especially depraved” meant that the perpetrator had relished the murder. During the sentencing hearing, the state argued that two aggravating circumstances existed because Walton had committed the murder in an especially heinous manner and for financial gain. Specifically, Walton and two others had intentionally looked for a victim to kidnap, rob, and carjack. Walton had escalated the crime to murder and left the victim alive in the desert to die many days later. Walton argued that his history of substance abuse, his exposure to abuse as a child, and his age of 20 were mitigating factors. The trial court determined that the aggravating circumstances existed and that the mitigating circumstances did not outweigh them. The court sentenced Walton to death. Walton appealed the death-penalty sentence. Among other arguments, Walton claimed that putting the burden on him to establish mitigating factors essentially created a presumption in favor of the death sentence, which made the sentence unconstitutionally cruel and unusual. Walton also claimed his Sixth Amendment right to a jury trial meant a jury, not a judge, must make all factual findings regarding aggravating and mitigating sentencing factors. The Arizona Supreme Court rejected these arguments and affirmed the sentence. The United States Supreme Court granted certiorari.