Ring v. Arizona

536 U.S. 584 (2002)

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Nature of the Case

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Facts

A Wells Fargo armored van pulled up to a Dillard's department store. Courier Dave Moss left the van to pick up money inside the store. When he returned, the van, and its driver, John Magoch, were gone. Sheriff's Deputies found the van and the dead body of Magoch. More than $562,000 in cash and $271,000 in checks were missing from the van. An informant's tip pointed to D and his friend James Greenham. Eventually, police tapped their phones executed a search warrant at D's house, discovering a duffel bag in his garage containing more than $271,000 in cash. D said the money seized at his house was startup capital for a construction company he and Greenham were planning to form. The jury deadlocked on premeditated murder, with 6 of 12 jurors voting to acquit, but convicted D of felony murder occurring in the course of armed robbery. Although clear evidence connected D to the robbery's proceeds, nothing submitted at trial put him at the scene of the robbery. Under Arizona law, D could not be sentenced to death, the statutory maximum penalty for first-degree murder, unless further findings were made. The judge who presided at trial was to 'conduct a separate sentencing hearing to determine the existence or nonexistence of [certain enumerated] circumstances . . . for the purpose of determining the sentence to be imposed.' The statute further instructs: 'The hearing shall be conducted before the court alone. The court alone shall make all factual determinations required by this section or the constitution of the United States or this state.' At the conclusion of the sentencing hearing, the judge is to determine the presence or absence of the enumerated 'aggravating circumstances' and any 'mitigating circumstances.' The State's law authorizes the judge to sentence the defendant to death only if there is at least one aggravating circumstance and 'there are no mitigating circumstances sufficiently substantial to call for leniency.' After D's trial, Greenham pleaded guilty to second-degree murder and armed robbery. He stipulated to a 27 1/2 year sentence and agreed to cooperate with the prosecution in the cases against D and Ferguson. Called by the prosecution at D's sentencing hearing, Greenham testified that he, D, and Ferguson had been planning the robbery for several weeks before it occurred. When Magoch opened the door to smoke a cigarette, Ring shot him with a rifle equipped with a homemade silencer. Greenham then pushed Magoch's body aside and drove the van away. The trial judge entered his 'Special Verdict' sentencing D to death. Because Ring was convicted of felony murder, not premeditated murder, the judge recognized that Ring was eligible for the death penalty only if he was Magoch's actual killer or if he was 'a major participant in the armed robbery that led to the killing and exhibited a reckless disregard or indifference for human life.' Citing Greenham's testimony at the sentencing hearing, the judge concluded that D 'is the one who shot and killed Mr. Magoch.' The judge also found that D was a major participant in the robbery and that armed robbery 'is unquestionably a crime which carries with it a grave risk of death.' The judge determined that D committed the offense in expectation of receiving something of 'pecuniary value,' and that the offense was committed 'in an especially heinous, cruel or depraved manner.' The judge cited Greenham's comment at the sentencing hearing, where D expressed pride in his marksmanship at the crime scene. The judge found one nonstatutory mitigating factor: D's 'minimal' criminal record. The judge sentenced D to death. On appeal, D argued that Arizona's capital sentencing scheme violates the Sixth and Fourteenth Amendments to the U.S. Constitution because it entrusts to a judge the finding of a fact raising the defendant's maximum penalty. The Arizona Supreme court rejected D's constitutional attack on the State's capital murder judicial sentencing system. The court agreed with D that the evidence was insufficient to support the aggravating circumstance of depravity, but it upheld the trial court's finding on the aggravating factor of pecuniary gain. The Arizona Supreme Court then reweighed that remaining factor against the sole mitigating circumstance (D's lack of a serious criminal record) and affirmed the death sentence. The Supreme Court granted certiorari.