State v. Mason
111 N.E.3d 432
| Ohio Ct. App. | 2016Background
- Maurice Mason was convicted in 1994 of aggravated murder with a death-penalty specification (aggravator: murder during rape) and sentenced to death; convictions were affirmed on direct appeal.
- Federal habeas proceedings led the Sixth Circuit in 2008 to grant a conditional writ vacating Mason’s death sentence and ordering resentencing (resentencing remained pending).
- After the U.S. Supreme Court decided Hurst v. Florida, Mason moved (2016) to dismiss the death-penalty specification, arguing Ohio’s capital statute is unconstitutional under Hurst.
- The trial court granted Mason’s motion and dismissed the capital specification, concluding Ohio’s sentencing scheme improperly vested factfinding with the judge.
- The State appealed under R.C. 2945.67(A); the appellate court reviewed de novo and reversed, holding Ohio’s 1993 scheme preserved the jury’s factfinding role and did not violate the Sixth Amendment.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Mason) | Held |
|---|---|---|---|
| Whether Ohio’s 1993 death-penalty statute violates the Sixth Amendment as interpreted in Hurst/Apprendi/Ring | Ohio: trial court should follow Ohio precedent (e.g., Belton/Hoffner) and reject a Hurst-based challenge; Ohio’s scheme is constitutional | Mason: Hurst requires a jury, not a judge, to find every fact necessary to impose death; Ohio’s judge makes the ultimate factual determination during sentencing | No — Ohio’s statute (1993) is constitutional; jury, not judge, finds the aggravating circumstance beyond a reasonable doubt, so Hurst does not invalidate Ohio’s scheme |
| Whether the jury’s weighing/recommendation in Ohio is merely advisory (and thus unconstitutional under Hurst) | State: Ohio’s jury makes the critical factfinding (aggravator) and its unanimous death recommendation is binding as to exposure to death; weighing is a moral judgment, not a Sixth Amendment factfinding | Mason: The trial judge’s reweighing and final written findings convert eligibility into a judicial factfinding, making the jury’s role advisory | No — the court held the jury’s finding of an aggravator makes the defendant death-eligible; weighing is not a factual finding that increases punishment |
| Whether Hurst created a new rule expanding Apprendi/Ring such that Ohio’s weighing violates the Sixth Amendment | State: Hurst applied Apprendi/Ring to Florida’s markedly different scheme; it did not change the Apprendi/Ring framework as applied to Ohio | Mason: Hurst overruled prior cases permitting judge-made factual findings at sentencing and therefore calls Ohio’s practice into question | Held for State — Hurst is an application of Apprendi/Ring to Florida’s scheme and does not disturb Ohio precedent where jury finds aggravators |
| Whether the trial court erred in failing to apply Supreme Court of Ohio precedent (Belton/Hoffner) | State: trial court should follow Ohio Supreme Court holdings that Ring/Hurst do not apply to Ohio’s statute because the jury determines aggravators | Mason: trial court viewed portions of Belton as dicta and claimed Ohio’s scheme still vests the judge with the decisive factual role | Held for State — trial court erred; it cannot refuse to follow higher-court precedent and Belton/Hoffner support Ohio’s constitutionality |
Key Cases Cited
- Hurst v. Florida, 577 U.S. _, 136 S.Ct. 616 (U.S. 2016) (invalidating Florida’s judge-centric capital factfinding and applying Apprendi/Ring)
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (any fact increasing prescribed punishment must be found by a jury)
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (Apprendi applied to capital cases; judge-alone factfinding for death violated Sixth Amendment)
- State v. Mason, 82 Ohio St.3d 144 (Ohio 1998) (affirming Mason’s convictions and death sentence on direct appeal)
- State v. Hoffner, 102 Ohio St.3d 358 (Ohio 2004) (holding Ring inapplicable to Ohio’s capital-sentencing scheme because jury, not judge, finds aggravators)
- State v. Gumm, 73 Ohio St.3d 413 (Ohio 1995) (defendant becomes death-eligible when factfinder finds aggravated murder plus statutory specification)
- State v. Cooey, 46 Ohio St.3d 20 (Ohio 1989) (only aggravating circumstances related to a given count may be considered in assessing penalty)