Oken v. State

HARRELL, Judge.

It is Maryland’s turn to consider the effect, if any, of the U.S. Supreme Court’s holding in Ring v. Arizona, 536 U.S. 584, 122 S.Ct. 2428, 153 L.Ed.2d 556 (2002), upon its capital punishment statutory scheme. At least eleven state supreme courts have preceded us in pondering the same question as regards their respective statutes.1 Of those states, four, Arizona, Colorado, Missouri, and Nevada, concluded that Ring *183compelled invalidation of some part of their statutes as written. The remaining six states, Alabama, California, Delaware, Florida, Illinois, and Oklahoma, concluded…