California v. Ramos
463 U.S. 992 (1983)
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Rule of Law:
The Eighth and Fourteenth Amendments do not prohibit a state from requiring a capital sentencing jury to be instructed on the governor's power to commute a sentence of life imprisonment without the possibility of parole, even if the instruction does not also mention the power to commute a death sentence.
Facts:
- Marcelino Ramos worked as a janitor at a fast-food restaurant.
- On the night of June 2, 1979, Ramos participated in an armed robbery of the restaurant.
- During the robbery, Ramos directed two employees into the restaurant's walk-in refrigerator.
- Inside the refrigerator, Ramos instructed the two employees to kneel and pray.
- Ramos then struck both employees on the head and shot them.
- One employee was wounded, and the other was killed as a result of the shooting.
Procedural Posture:
- Marcelino Ramos was charged with robbery, attempted murder, and first-degree murder in a California trial court.
- A jury convicted Ramos on all counts and, after a separate penalty phase, returned a verdict of death.
- During the penalty phase, the trial judge gave the 'Briggs Instruction,' informing the jury of the governor's power to commute a life sentence without parole.
- Ramos (appellant) appealed the death sentence to the Supreme Court of California.
- The Supreme Court of California affirmed the conviction but reversed the death sentence, holding that the Briggs Instruction violated the U.S. Constitution.
- The State of California (petitioner) successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a state law requiring a capital sentencing jury to be instructed that a sentence of life imprisonment without possibility of parole may be commuted by the governor violate the Eighth and Fourteenth Amendments of the U.S. Constitution?
Opinions:
Majority - Justice O’Connor
No. The Eighth and Fourteenth Amendments do not prohibit a state from requiring a capital sentencing jury to be instructed on the governor's power to commute a life sentence. The Court defers to a state's choice of substantive factors relevant to the penalty determination, provided they do not run afoul of established constitutional constraints. The Court's reasoning is that this instruction is analogous to considering a defendant's future dangerousness, a factor upheld in Jurek v. Texas. By informing the jury of the commutation power, the instruction invites them to assess whether the defendant's potential return to society is desirable, which is a valid consideration for a sentencing body. Furthermore, the instruction provides accurate information, correcting the potential misconception that a sentence of 'life without possibility of parole' is absolute and unchangeable. The failure to also inform the jury of the governor's power to commute a death sentence is not a constitutional defect, as such an instruction could prejudice the defendant by diminishing the jury's sense of responsibility for its life-or-death decision.
Dissenting - Justice Marshall
Yes. The instruction is unconstitutional because it is misleading, invites speculation, and injects an irrelevant factor into the capital sentencing process. The instruction is a misleading 'half-truth' that suggests to the jury that a death sentence is the only way to ensure the defendant is permanently removed from society, which is false since a death sentence can also be commuted. It unconstitutionally invites the jury to engage in 'sheer speculation' about the future actions of governors and parole boards, which has no reliable basis and leads to arbitrary and capricious sentencing. The possibility of commutation is entirely unrelated to the defendant's character or the nature of the crime, which should be the central focus of a capital sentencing decision. The vast majority of state courts that have considered the issue have prohibited such instructions, a consensus the majority wrongly ignores.
Dissenting - Justice Blackmun
Yes. The majority fundamentally mischaracterizes the issue and avoids proper legal analysis. The instruction is about the probability of a governor's future action, not the defendant's future dangerousness. By equating the two, the Court engages in an 'intellectual sleight of hand' rather than confronting the actual constitutional question of whether a jury can be told about the governor's commutation power. This flawed reasoning compounds the unfairness of the instruction itself.
Dissenting - Justice Stevens
Yes. The instruction is fundamentally wrong, and the Court should not have granted certiorari to hear the case in the first place. The governor's power to commute a sentence is entirely irrelevant to the defendant's culpability or capacity for rehabilitation, which are the proper considerations for a jury. The instruction wrongly encourages the jury to resolve any doubt in favor of death simply to ensure the defendant is never released, rather than based on the circumstances of the crime or the offender. The Court's decision to overturn the California Supreme Court, which had followed the overwhelming consensus of other states, represents an unwise use of judicial discretion aimed at facilitating the imposition of the death penalty.
Analysis:
This decision reinforces the Supreme Court's deference to state legislative choices regarding the substantive factors juries can consider in capital sentencing. It broadens the scope of permissible information by equating the governor's clemency power with the defendant's future dangerousness, a concept approved in Jurek v. Texas. The ruling stands in stark contrast to the overwhelming majority of state court decisions, signaling the Court's willingness to permit states to introduce factors that may increase the likelihood of a death sentence, even if those factors are speculative and not directly related to the defendant's character or crime.
