Murdaugh v. Ryan

Under the Sixth Amendment, a jury must weigh aggravating versus mitigating factors in applying an aggravating sentencing bonus.

Michael Murdaugh, on a methamphetamine binge, bludgeoned David Reynolds to death for propositioning his girlfriend to perform oral sex. Murdaugh then dismembered Reynolds' body and disposed of it in a rural area. The police questioned Murdaugh and noticed a similar modus operandi to the unsolved killing of Douglas Eggert; Murdaugh confessed to that murder as well. Murdaugh wished to plead guilty to avoid dragging his family through a trial. Additionally, Murdaugh waived the right to present mitigating evidence. The trial court permitted state prosecutors to include mitigating evidence that emphasized the aggravating nature of the crime while diminishing testimony regarding substance abuse and diminished capacity during the crime. The lower court judge determined that Murdaugh had committed aggravated murder, and Murdaugh filed a habeas corpus plea under Ring v. Arizona, which held that under the Sixth Amendment, an “aggravated” distinction must be made by the jury and not a judge. After Murdaugh’s habeas corpus plea was denied, the Ninth Circuit reviewed the habeas corpus question de novo and the competency ruling for abuse of discretion. The panel concluded that the trial court did not appropriately apply Ring by allowing a jury to balance the aggravating and mitigating factors and that the error had a significantly injurious effect vis-a-vis the death sentence. The panel alluded that a jury could have found a causal connection between the aggravating and mitigating factors. The panel found that Murdaugh's subsequent claim was precluded based on his own waiver for his counsel to present mitigating evidence. REVERSED in part, AFFIRMED in part, and REMANDED.