 It would be another eight years before he would first express his view that every fact necessary to a criminal defendant's punishment must be submitted to a jury and proved beyond a reasonable doubt, and six more years after that before that view would become fully articulated as the law of the land.In two earlier decisions, the Court had ruled that aggravating factors imposing the death penalty where the murder was "outrageously or wantonly vile, horrible, or inhuman," or where the murder was "especially heinous, atrocious, or cruel," was unconstitutionally vague.In "Walton", however, the Court reversed this trend and upheld Arizona's "especially heinous, cruel, or depraved" aggravating factor against a similar challenge.