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No. 18-1109October Term 2019Decided Feb 25, 2020

Docket 18-1109October Term 2019 (2019–2020)

McKinney v. Arizona

The Supreme Court said Arizona could fix McKinney's sentencing error through appellate reweighing rather than automatically giving him a new jury sentencing proceeding.

Case status

Current stage
Decided
Latest event
Decision released Feb 25, 2020
Case Accepted
Arguments
Decision ReleasedFeb 25, 2020
What it's about

This death penalty case asked what Arizona had to do after a federal habeas court ruled that the state had failed to properly consider James McKinney’s mitigating evidence, including his PTSD, at sentencing. The issue was whether the Arizona Supreme Court could fix that error by reweighing the aggravating and mitigating evidence itself, or whether McKinney had to receive a new jury sentencing proceeding under current law.

Question 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?

Case path

Supreme Court of Arizona / Decision released Feb 25, 2020

Area

Criminal Procedure

Briefing

What it's about

This case asked how Arizona had to fix a death sentence after a federal habeas court said the state failed to properly consider James McKinney's mitigating evidence, including PTSD. The Supreme Court said an appellate court may correct that kind of error by reweighing the aggravating and mitigating evidence, instead of automatically ordering a new jury sentencing proceeding.

Vote

The Court decided that appellate reweighing is a permissible way to correct this Eddings error. The prompt does not provide the vote count or opinion lineup.

Impact

The decision affects how states can fix sentencing mistakes in death penalty cases. For example, a state supreme court may be able to redo the weighing itself rather than send the case back for a full new sentencing hearing.

What's next

The Supreme Court has finished this case. Any further proceedings would take place in Arizona courts under the rule the Court announced.

What was the main fight in McKinney v. Arizona?

The dispute was over how Arizona had to correct a sentencing error after courts failed to properly consider McKinney's mitigating evidence. The key question was whether appellate judges could reweigh the evidence themselves.

Why does McKinney v. Arizona matter beyond this one case?

It affects other death penalty cases where a court later finds a sentencing mistake. States may use appellate reweighing instead of always starting a new sentencing proceeding.

What happens next after the Supreme Court's decision in McKinney v. Arizona?

The Supreme Court's review is over. Any remaining action would happen in Arizona courts following the Court's decision.

Decision

Decision record

What the Court decided

The Supreme Court said Arizona could fix McKinney's sentencing error through appellate reweighing rather than automatically giving him a new jury sentencing proceeding.

Impact

The decision affects how states can fix sentencing mistakes in death penalty cases. For example, a state supreme court may be able to redo the weighing itself rather than send the case back for a full new sentencing hearing.

Not official Court text.

Opinion documents