In Ring v. Arizona, 536 U.S. 584 (2002), the Court applied the reasoning of Apprendi v. New Jersey to Arizona's death penalty statute to determine the Sixth Amendment right to a jury trial in a capital prosecution. The Arizona law, which the Court had previously upheld against such a challenge in Walton v. Arizona, 497 U.S. 639 (1990), provided that following a jury's adjudication of a defendant's guilt of first degree murder, the trial judge must hold a nonjury sentencing hearing to determine the presence or absence of the aggravating factors required by Arizona law as prerequisites for imposition of the death penalty. Based upon testimony received at the sentencing hearing, but not during the trial before the jury, the sentencing judge had found the existence of aggravating factors beyond a reasonable doubt predominating over the mitigating circumstance and imposed a sentence of death. Finding that Apprendi and Walton were irreconcilable, the Court reversed the conviction. It held that "capital defendants, no less than noncapital defendants . . . are entitled to a jury determination of any fact on which the legislature conditions an increase in their maximum punishment." (Id. at 589.) Rejecting the notion that a legislative labeling of an enhancing factor as a "sentencing factor" rather than as an "element of the crime" would be dispositive for Sixth Amendment analysis, the Supreme Court stated: "If a State makes an increase in a defendant's authorized punishment contingent on the finding of a fact, that fact--no matter how the State labels it--must be found by a jury beyond a reasonable doubt." (Id. at 602.) The United States Supreme Court invalidated Arizona's death penalty scheme, which allowed the sentencing judge to determine whether an aggravating circumstance had been proven. The Supreme Court held that "if a State makes an increase in a defendant's authorized punishment contingent on the finding of a fact, that fact--no matter how the State labels it--must be found by a jury beyond a reasonable doubt." (Ring at 585-586.) The Court held that "all facts essential to imposition of the level of punishment that the defendant receives--whether the statute calls them elements of the offense, sentencing factors, or Mary Jane--must be found by the jury beyond a reasonable doubt" (Ring at 610.) The Supreme Court followed Apprendi to invalidate a scheme whereby, after the jury found guilt, the judge determined the presence or absence of aggravating factors required by state law for imposition of the death penalty. The high court explained: "We held that Apprendi's sentence violated his right to 'a jury determination that he is guilty of every element of the crime with which he is charged, beyond a reasonable doubt.' That right attached not only to Apprendi's weapons offense but also to the 'hate crime' aggravating circumstance ... . The dispositive question ... 'is one not of form, but of effect.' If a State makes an increase in a defendant's authorized punishment contingent on the finding of a fact, that fact--no matter how the State labels it--must be found by a jury beyond a reasonable doubt. A defendant may not be 'exposed ... to a penalty exceeding the maximum he would receive if punished according to the facts reflected in the jury verdict alone.'" (Ring, at p. 602.) The court concluded: "Because Arizona's enumerated aggravating factors operate as 'the functional equivalent of an element of a greater offense,' the Sixth Amendment requires that they be found by a jury." (Ring, at p. 609.)