Schriro v. Summerlin
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In Schriro v. Summerlin, 542 U.S. 348 (2004), the Supreme Court held that Ring v. Arizona, 536 U.S. 584 (2002), which extended Apprendi's jury trial requirement to the aggravating circumstances that make a defendant eligible for the death penalty, is not retroactive for other cases because deprivation of the jury trial right does not seriously diminish the accuracy of a criminal proceeding.