McKinney v. Arizona
McKinney v. Arizona, 589 U.S. ___, is a Supreme Court of the United States decision in which the court held that an appellate court—not a jury—must reweigh the mitigating and aggravating factors in a death-penalty habeas corpus case after an Eddings error is identified. An Eddings error is when a person deciding a sentence in a capital punishment does not consider all mitigating evidence.
Background
James Erin McKinney, along with his half-brother Charles Michael Hedlund, committed two counts of burglary which resulted in two deaths. After being prosecuted by the State of Arizona, McKinney was found guilty of two counts of First Degree Murder. At sentencing, a psychologist testified that he had diagnosed McKinney with post-traumatic stress disorder, with the sentencing judge stating that McKinney's childhood was “beyond the comprehension of most people.” Arizona state law prevented the judge from considering this as it had no direct relevance to the crime and McKinney was thus sentenced to death.On appeal in 2018, the Arizona Supreme Court upheld the death sentence. It was then appealed to the United States Supreme Court over disagreements on whether a judge or jury should resentence the defendant. As of April 2021, both McKinney and Hedlund are among 20 Arizona death row inmates who have exhausted all their appeals.