Increasing Penalty for a Crime Beyond Statutory Maximum Must Be Submitted to the Jury and Proven Beyond Doubt

In Apprendi v. New Jersey, 530 U.S. 466, 120 S.Ct. 2348, 147 L.Ed.2d 435 (2000), the Supreme Court held that any fact that increases the penalty for a crime beyond the statutory maximum must be submitted to a jury and proven beyond a reasonable doubt. Subsequently, in Ring v. Arizona, 536 U.S. 584, 122 S.Ct. 2428, 153 L.Ed.2d 556 (2002), the Supreme Court ruled that Apprendi is applicable in the death penalty context. Accordingly, the Supreme Court found the Arizona capital sentencing statute at issue in Ring to be unconstitutional "to the extent that it allows a sentencing judge, sitting without a jury, to find an aggravating circumstance necessary for the imposition of the death penalty." Id. at 2443.