McKinney v. Arizona
McKinney v. Arizona, 589 U.S. ___ (2020) is a Supreme Court of the United States decision concerning how an appellate court handles sentencing after an Edding's error is identified – an error in which a person deciding a sentence in a capital punishment does not consider all mitigating evidence. It ruled that the state appellate court, rather than a jury, should reweigh the mitigating and aggravating factors in a habeas corpus review.
McKinney v. Arizona | |
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Argued December 11, 2019 Decided February 25, 2020 | |
Full case name | James Erin McKinney v. State of Arizona |
Docket no. | 18-1109 |
Citations | 589 U.S. ___ (more) |
Argument | Oral argument |
Court membership | |
| |
Case opinions | |
Majority | Kavanaugh, joined by Roberts, Thomas, Alito, Gorsuch |
Dissent | Ginsburg, joined by Kagan, Breyer, Sotomayor |
Background
James Erin McKinney, along with his half-brother Charles Michael Hedlund, committed two counts of burglary which resulted in two deaths.[1] After being prosecuted by the State of Arizona, McKinney was found guilty of two-counts of First Degree Murder. At sentencing, a psychologist testified that he had diagnosed McKinney with post-traumatic stress disorder with the sentencing judge stating that McKinney's childhood was “beyond the comprehension of most people”. [2] Arizona state law prevented the judge from considering this as it had no direct relevance to the crime and McKinney was thus sentenced to death.[3]
On appeal in 2018, the Arizona Supreme Court upheld the death sentence.[4] It was then appealed to the United States Supreme Court over disagreements on weather a judge or jury should resentence the defendant.[3][5]
Decision
The Court ruled 5–4 that the state appellate court may reweigh the aggravating and mitigating factors.[3]
References
- Wolf, Richard. "Supreme Court denies new sentencing hearing for Arizona murderer". USA TODAY. Retrieved December 14, 2020.
- "McKinney v. Arizona". Death Penalty Information Center. Retrieved December 13, 2020.
- "McKinney v. Arizona". Oyez. Retrieved December 13, 2020.
- Sheldon, Hon. Steven Douglas (2018). State of Arizona v. James Erin McKinney (PDF). Arizona: Supreme Court of Arizona.
- "NCJRS Abstract – National Criminal Justice Reference Service". www.ncjrs.gov. Retrieved December 13, 2020.