Supreme Court Ruling in Sentencing Case Limits the Rights of Defendants
From: Civil Rights Monitor Vol. 10, No. 3 (Summer 1999)
On June 21, 1999, the Supreme Court ruled 5-4 that a judge is not required to inform a juror panel of the consequences of its inability to reach agreement on the sentence of a convicted criminal. Specific to this case, the court was not required to tell jurors that if they deadlocked on a sentence of death or life imprisonment, the judge would mandate the life sentence as opposed to a lighter penalty. The decision Jones v. United States will make it more difficult for prisoners to appeal the severity of their sentences by arguing that their juries did not receive correct instructions.
Background
The case was brought by Louis Jones, who in 1995 was convicted and sentenced to death by a unanimous jury for the kidnaping, rape and murder of Tracie Joy McBride. Because the kidnaping occurred on an Air Force base where McBride was a private, Jones was prosecuted under federal law. He was the first person sentenced to die under a 1994 federal law extending capital punishment to forty additional crimes.
After Jones' conviction, the only sentencing options were the death penalty or life in prison without the possibility of release. However, in his instructions to the jury, the judge incorrectly told the jurors that Jones could also be sentenced to "some other lesser sentence." Jones argued that the false information made the jurors think that Jones might end up with a lighter sentence and eventually be released from prison if they did not agree on the death penalty.
Opinion
In a close decision, the Supreme Court ruled that it is not necessary for the jury to know the consequences if they deadlock in their decision. Justice Thomas wrote the opinion of the Court, joined by Chief Justice Rehnquist and Justices Scalia, O'Connor, and Kennedy. Thomas explained that the Eighth Amendment requires that if a jury deadlocks, the judge decides the sentence. However, the opinion points out, "the Eighth Amendment does not require that the jury be instructed as to the consequences of their failure to agree," because "such an instruction has no bearing on the jury's role in the sentencing process." In addition, Thomas wrote, "the government has a strong interest in having the jury express the conscience of the community on the ultimate question of life and death," and "a charge to the jury of the sort proposed by [Jones] might well have the effect of undermining this strong governmental interest."
In addition, the majority disagreed with Jones that the jurors were confused and might have believed that if they reached a stalemate, Jones would have received a lighter sentence. The Court pointed out that even if the jurors were indeed confused, Jones did not convince the Court that the misunderstanding hurt his case or affected his rights.
Justice Ginsburg wrote the dissent, joined by Justices Souter, Stevens, and Breyer. In dissent, Ginsburg wrote that the Court's "tolerance for flaws" in this case does not follow the court's rule that "accurate sentencing information is an indispensable prerequisite to a jury's determination of whether a defendant shall live or die." She also asserted that the "jury's choice was clouded by . . . misinformation. . . . [A] jury may be swayed toward death if it believes the defendant otherwise may serve less than life in prison." In light of this, the dissent argued that the case should be returned to the lower court and the sentence reconsidered by "an accurately informed trier."
