Brown v. Sanders
2006 U.S. LEXIS 760, 546 US 212, 163 L. Ed. 2d 723 (2006)
Rule of Law:
An invalidated sentencing factor in a capital case does not render a death sentence unconstitutional if one of the other valid sentencing factors enabled the jury to give aggravating weight to the same facts and circumstances that underpinned the invalidated factor.
Facts:
- Ronald Sanders and a companion invaded the home of Dale Boender.
- They bound and blindfolded Boender and his girlfriend, Janice Allen.
- Both victims were struck on the head with a heavy, blunt object.
- Janice Allen died from the blow she received.
Procedural Posture:
- A California state jury convicted Ronald Sanders of first-degree murder and found four 'special circumstances' true, making him eligible for the death penalty.
- The jury sentenced Sanders to death.
- On direct appeal, the California Supreme Court invalidated two of the four special circumstances but affirmed the death sentence.
- Sanders filed a petition for a writ of habeas corpus in the U.S. District Court for the Eastern District of California, which was denied.
- Sanders, as appellant, appealed to the U.S. Court of Appeals for the Ninth Circuit, which reversed the district court's denial of habeas relief, finding the sentence unconstitutional.
- The State of California, through warden Brown as petitioner, was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does a death sentence violate the Eighth Amendment when two of four death-eligibility factors considered by the jury are later invalidated on appeal, but the facts underlying those invalid factors were also admissible and properly considered by the jury under a separate, valid, omnibus sentencing factor such as 'the circumstances of the crime'?
Opinions:
Majority - Justice Scalia
No. A death sentence in this circumstance does not violate the Eighth Amendment because the jury’s consideration of the invalidated factors did not unconstitutionally skew the sentencing process. The Court establishes a new rule, moving away from the complex 'weighing' versus 'non-weighing' state distinction. The proper inquiry is whether the invalidated factor allowed the sentencer to consider facts that were not otherwise admissible or relevant to another valid factor. In this case, California’s sentencing scheme includes the broad factor allowing consideration of '[t]he circumstances of the crime.' This omnibus factor permitted the jury to properly consider all the evidence related to the murder, including the facts that supported the invalidated 'burglary-murder' and 'heinous, atrocious, or cruel' special circumstances. Therefore, since the jury could have given the same aggravating weight to the same facts under a valid factor, no constitutional error occurred.
Dissenting - Justice Stevens
Yes. The death sentence is unconstitutional because California is a weighing state, and invalidating two aggravating factors presumptively taints the jury's weighing process. The majority wrongly abandons the weighing/non-weighing distinction in favor of a new rule focused only on the admissibility of evidence. This new rule ignores the powerful effect of formally labeling certain facts as a statutory 'aggravating circumstance.' When a jury is explicitly instructed to weigh an invalid factor, like the murder being 'heinous, atrocious, or cruel,' it may improperly double-count the evidence or give it undue weight due to its legislative imprimatur. This places a 'thumb on death's side of the scale' that cannot be presumed harmless.
Dissenting - Justice Breyer
The Court's approach is incorrect; a reviewing court must always conduct a harmless-error analysis when a jury considers an invalid aggravating factor, regardless of a state's statutory scheme. The weighing/non-weighing distinction is 'unrealistic, impractical, and legally unnecessary' because the risk of prejudice exists in both systems. The majority’s new rule is also flawed because it focuses solely on the admissibility of the underlying evidence, ignoring the crucial problem of the improper 'emphasis' the state places on that evidence by labeling it a formal aggravator. Citing Clemons v. Mississippi, the dissent argues that the key constitutional concern is the potential for bias from the 'thumb on the scale,' which can only be assessed through a case-specific harmless-error review, not a categorical rule based on evidence admissibility.
Analysis:
This decision significantly simplifies and alters the Court's capital sentencing jurisprudence by discarding the complex weighing/non-weighing state framework. It replaces that analysis with a more straightforward test focused on whether the evidence underlying an invalid aggravator was otherwise admissible under a valid one. This makes it substantially more difficult for defendants to challenge death sentences based on invalidated factors, especially in states with an omnibus 'circumstances of the crime' factor. The ruling effectively narrows the definition of constitutional error in this context, shifting the focus from the formal instructions and labels given to the jury to the substantive evidence they were permitted to consider.
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