Justice Ruth Bader Ginsburg wrote a dissent which Justices Stephen Breyer, Elana Kagan, and Sonia Sotomayor joined. Under this interpretation of the Arizona Supreme Court’s actions, McKinney was not entitled to a jury sentencing because his conviction became final before Ring v. In doing so, he accepted the state’s assertion that independent reweighings conducted after a defendant’s initial appeal are not considered direct review proceedings. Justice Kavanaugh also rejected McKinney’s argument that the Arizona Supreme Court’s independent review of the case reopened the direct appeal process. Florida, “a jury (as opposed to a judge) is not constitutionally required to weigh the aggravating and mitigating circumstances.” Justice Kavanaugh stated that notwithstanding the Court’s rulings in Ring v. He further found that the reasoning relied upon in Clemons was not affected by the court’s more recent decisions about jury sentencing. Justice Kavanaugh concluded that a supreme court could conduct the same reweighing to remedy a deficiency in the consideration of mitigating circumstances. Mississippi, which allowed a state supreme court to reweigh evidence if one of the aggravating circumstances on which a death sentence relied was later invalidated. In a majority opinion written by Justice Brett Kavanaugh, the Court held that McKinney’s Eddings argument was foreclosed by an earlier Supreme Court case, Clemons v. Supreme Court rejected McKinney’s arguments and let his death sentences stand. In his petition for certiorari, McKinney challenged the Arizona Supreme Court’s ruling, arguing that correcting an Eddings error about consideration of mitigation evidence requires a resentencing, not just state supreme court review. In doing so, the court gave McKinney’s PTSD little weight. Following the Ninth Circuit’s decision, the Arizona Supreme Court upheld the death sentence after reweighing the aggravating and mitigating evidence. The Ninth Circuit found that Arizona’s practice (in McKinney’s cases and all other cases decided in a 15-year time period) violated the Supreme Court’s decision in Eddings v. McKinney’s death sentence was found unconstitutional in 2015 by the Ninth Circuit Court of Appeals because Arizona courts refused to consider mitigating evidence without a “causal nexus” to the crime. On direct appeal, the Arizona Supreme Court conducted an independent review and affirmed the death sentence. While the trial judge in McKinney’s case recognized that McKinney’s childhood was so horrific that it was “beyond the comprehension of most people,” the judge dismissed this evidence because he found it was not causally connected to the crime. This severe childhood abuse resulted in McKinney being diagnosed with posttraumatic stress disorder (“PTSD”).Īt the time McKinney was tried, Arizona did not allow for jury sentencing in death penalty cases. McKinney’s mitigation evidence included evidence of a childhood filled with instability, abuse, and neglect. McKinney was sentenced to death in 1993 for the killings of two people in the course of a series of burglaries. In a 5-4 decision, the Supreme Court declined to overturn James Erin McKinney’s Arizona death sentences.
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