Judge Jose Martinez, a George W. Bush appointee, relied on a 2002 U.S. Supreme Court decision barring judges from interpreting “aggravating factors” independent of juries’ explicit findings.
ring v. arizona
Ring v. Arizona 536 US 584 (2002): Capital Punishment and Sixth Amendment Law
In Ring v. Arizona, Arizona’s capital sentencing system was found to violate the Sixth Amendment’s guarantee of a trail by jury by shifting the imposition of the death sentence to a judge.