Ring v. Arizona

Background & Context

Timothy Ring and two accomplices robbed an armored truck in Maricopa County, Arizona in November 1994, killing the driver, John Magoch. Ring was convicted of first-degree murder. Under Arizona law at the time, a judge — not the jury — determined whether to impose the death penalty. After the jury returned its guilty verdict, the trial judge held a separate sentencing hearing and found two aggravating circumstances: that the murder was committed for financial gain and that it was especially heinous or cruel. Based on those findings, the judge sentenced Ring to death. Ring challenged his death sentence, arguing that requiring a judge — rather than the jury — to find the aggravating facts that made him death-eligible violated the Sixth Amendment right to jury trial. He relied on Apprendi v. New Jersey (2000), in which the Supreme Court had held that any fact that increases a defendant's maximum sentence beyond what the jury's verdict alone supports must be submitted to the jury and proved beyond a reasonable doubt. Arizona's sentencing scheme was the most extreme version of a common practice: 9 states used judge-only capital sentencing schemes at the time. Under Walton v. Arizona (1990), the Supreme Court had previously upheld Arizona's judge-sentencing system. Ring's lawyers argued that Apprendi had effectively overruled Walton. Arizona responded that the Court had explicitly preserved Walton in Apprendi itself, and that death penalty sentencing remained a constitutionally special category that the Apprendi rule did not reach.