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McKinney v. Arizona

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Supreme Court of the United States
McKinney v. Arizona
Term: 2019
Important Dates
Argument: December 11, 2019
Decided: February 25, 2020
Outcome
Affirmed
Vote
5-4
Majority
Brett Kavanaugh • Chief Justice John G. Roberts • Clarence Thomas • Samuel Alito • Neil Gorsuch
Dissenting
Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan


McKinney v. Arizona is a case argued before the Supreme Court of the United States on December 11, 2019, during the court's October 2019-2020 term. The case came on a writ of certiorari to the Arizona Supreme Court.[1]

The court affirmed the decision of the Arizona Supreme Court in a 5-4 ruling, holding that a state appellate court, rather than a jury, may conduct a reweighing of aggravating and mitigating circumstances on habeas corpus review in cases concerning the death penalty.[1][2] Click here for more information.

HIGHLIGHTS
  • The case: In 1993, James McKinney was convicted of first-degree murder and sentenced to death. The Arizona Supreme Court affirmed the sentence after an independent review. A federal district court denied McKinney's petition for habeas corpus. On appeal, the 9th Circuit instructed the district court to grant the habeas corpus petition. After another independent review, the Arizona Supreme Court affirmed the death sentences.[3]
  • The issue: (1) Whether the Arizona Supreme Court was required to apply current law when weighing mitigating and aggravating evidence to determine whether a death sentence is warranted. (2) Whether the correction of error under Eddings v. Oklahoma, 455 U.S. 104 (1982), requires resentencing.[4]
  • The outcome: In a 5-4 opinion, the court affirmed the Arizona Supreme Court's ruling, holding that a state appellate court, rather than a jury, may conduct a reweighing of aggravating and mitigating circumstances on habeas corpus review in cases concerning the death penalty.[1][2]


    • You can review the lower court's opinion here.[3]

    Timeline

    The following timeline details key events in this case:

    • February 25, 2020: U.S. Supreme Court affirmed the Arizona Supreme Court's ruling.
    • December 11, 2019: Oral argument
    • June 10, 2019: The U.S. Supreme Court agreed to hear the case.
    • February 21, 2019: James McKinney filed a petition with the U.S. Supreme Court.
    • September 27, 2018: The Arizona Supreme Court affirmed McKinney's death sentences.

    Background

    In March 1991, James McKinney and his half-brother, Charles Hedlund, robbed the home of Christine Mertens. During the robbery, McKinney killed Mertens. Two weeks later, the brothers robbed the home of Jim McClain, also killing McClain in the process. In 1993, a jury found McKinney guilty of first-degree murder as to both victims.[3]

    During the sentencing phase, the court found several aggravating and mitigating circumstances. The trial court found the circumstances were not sufficient to call for leniency, and McKinney was sentenced to death. The Arizona Supreme Court affirmed the sentence after an independent review. McKinney petitioned for habeas corpus but the federal district court denied. On appeal, the United States Court of Appeals for the 9th Circuit reversed and remanded the case, instructing the district court to grant the petition for habeas corpus.[3]

    After another independent review, the Arizona Supreme Court affirmed the death sentences.[3]

    McKinney petitioned the U.S. Supreme Court to review the case. In the petition, McKinney argued, "By refusing to remand McKinney’s case for resentencing, the Arizona Supreme Court created a clear split with five other state and federal courts."[5]

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:

    (1) Whether the Arizona Supreme Court was required to apply current law when weighing mitigating and aggravating evidence to determine whether a death sentence is warranted.

    (2) Whether the correction of error under Eddings v. Oklahoma, 455 U.S. 104 (1982), requires resentencing.[4]

    Outcome

    In a 5-4 opinion, the court affirmed the judgment of the Arizona Supreme Court, holding that a state appellate court, rather than a jury, may conduct a reweighing of aggravating and mitigating circumstances on habeas corpus review in cases concerning the death penalty. Justice Brett Kavanaugh delivered the opinion of the court.[2]

    Opinion

    In his opinion, Justice Kavanaugh wrote:[2]

    “ A Clemons reweighing is a permissible remedy for an Eddings error, and when an Eddings error is found on collateral review, a state appellate court may conduct a Clemons reweighing on collateral review. McKinney’s argument that a jury must resentence him does not square with Clemons, where the Court held that a reweighing of the aggravating and mitigating evidence may be conducted by an appellate court. ... Because Clemons involved an improperly considered aggravating circumstance, McKinney maintains that it is inapposite here, where the case involves an improperly ignored mitigating circumstance. Clemons, however, did not depend on any unique effect of aggravators as distinct from mitigators. For purposes of appellate reweighing, there is no meaningful difference between subtracting an aggravator from one side of the scale and adding a mitigator to the other side. McKinney also argues that Clemons is no longer good law in the wake of Ring v. Arizona, and Hurst v. Florida, where the Court held that a jury must find the aggravating circumstance that makes the defendant death eligible.


    But that does not mean that a jury is constitutionally required to weigh the aggravating and mitigating circumstances or to make the ultimate sentencing decision within the relevant sentencing range. ... McKinney notes that the Arizona trial court, not the jury, made the initial aggravating circumstance finding that made him eligible for the death penalty. But McKinney’s case became final on direct review long before Ring and Hurst, which do not apply retroactively on collateral review, ... and the Arizona Supreme Court’s 2018 decision reweighing the aggravators and mitigators did not constitute a reopening of direct review.[6]

    		”

    Dissenting opinion

    Justice Ruth Bader Ginsburg filed a dissenting opinion, joined by Justices Stephen Breyer, Sonia Sotomayor, and Elena Kagan.[2]

    In her dissent, Justice Ginsburg wrote:[2]

    “ Petitioner James Erin McKinney, convicted in Arizona of two counts of first-degree murder, was sentenced to death in 1993. At that time, Arizona assigned capital sentencing to trial judges. To impose a death sentence, the judge had to find at least one aggravating circumstance and “no mitigating circumstances sufficiently substantial to call for leniency.” ... In 2002, in Ring v. Arizona, this Court held Arizona’s capital sentencing regime unconstitutional. The “aggravating factors” that render a defendant eligible for capital punishment in Arizona, the Court reasoned, “operate as ‘the functional equivalent of an element of a greater offense.’” ... “[T]he Sixth Amendment [therefore] requires that [such aggravating factors] be found by a jury.” ... see Hurst v. Florida ... Here in dispute, does Ring apply to McKinney’s case? If it does, then McKinney’s death sentences—imposed based on aggravating factors found by a judge, not a jury—are unlawful. ...


    Because Ring controls post-2002 direct review proceedings, I would apply that precedent here and reverse the judgment of the Arizona Supreme Court.[6]

    		”

    Text of the opinion

    Read the full opinion here.[2]


    Oral argument

    Audio

    Audio of oral argument:[7]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 SCOTUSblog, "McKinney v. Arizona," accessed February 25, 2020
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 Supreme Court of the United States, McKinney v. Arizona, decided February 25, 2020
    3. ↑ 3.0 3.1 3.2 3.3 3.4 Arizona Supreme Court, State of Arizona v. James Erin McKinney, decided September 27, 2018
    4. ↑ 4.0 4.1 Supreme Court of the United States, "Questions presented: 18-1109 McKinney v. Arizona," accessed June 11, 2019
    5. ↑ Supreme Court of the United States, "Petition for a writ of certiorari," accessed June 11, 2019
    6. ↑ 6.0 6.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed December 16, 2019
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