## Facts

- Timothy Stuart Ring was tried in Arizona for murder and related offenses arising from an armed robbery of an armored car in Glendale, Arizona, during which the driver was shot and killed.
- The jury deadlocked on premeditated murder but convicted Ring of felony murder committed in the course of armed robbery.
- Under Arizona’s capital sentencing scheme, a death sentence could be imposed only if, after a separate hearing, a judge found at least one statutory aggravating circumstance and concluded that mitigation was not sufficiently substantial to warrant leniency.
- Because the conviction was for felony murder, death eligibility also depended on a finding that Ring was the actual killer.
- At sentencing, the judge found Ring was the actual killer, found aggravating circumstances (including that the offense was committed for pecuniary gain), found limited mitigation (minimal criminal record), and imposed a death sentence.
- The Arizona Supreme Court affirmed, treating prior Supreme Court precedent as controlling despite doubts raised by more recent Sixth Amendment decisions.

## Issues

1. Whether the Sixth Amendment permits a sentencing judge, rather than a jury, to find an aggravating circumstance required to authorize imposition of the death penalty.
2. Whether statutory aggravating factors that make a defendant death-eligible are facts that must be found by a jury beyond a reasonable doubt because they increase the maximum punishment authorized by the jury’s verdict.

## Decision

- The Supreme Court held, 7–2, that Arizona’s capital sentencing scheme violated the Sixth Amendment.
- The Court ruled that a judge sitting without a jury may not find an aggravating circumstance necessary to impose the death penalty.
- The Court concluded that Arizona’s aggravating factors operate as the functional equivalent of elements of a greater offense and therefore must be found by a jury beyond a reasonable doubt.
- The Court overruled prior precedent to the extent it allowed judge-found aggravating circumstances as a basis for death eligibility.

## Legal Principles

- Any fact that increases the maximum punishment authorized by the jury’s verdict must be submitted to a jury and proved beyond a reasonable doubt.
- For Sixth Amendment purposes, the “statutory maximum” is the maximum sentence permitted based solely on the facts reflected in the jury verdict.
- In capital sentencing, aggravating circumstances that must be found before the death penalty may be imposed function as elements and are subject to the jury-trial requirement.
- A state may not make a defendant death-eligible through judicial fact-finding of required aggravators.

## Conclusion

The Court required that juries, not judges, determine beyond a reasonable doubt any aggravating facts necessary to authorize a death sentence, invalidating Arizona’s judge-centered death-penalty eligibility procedure and overruling contrary precedent in that respect.


Ring v. Arizona, 536 U.S. 584 (2002)