Mills v. Maryland

Supreme Court of United States
486 U.S. 367 (1988)

ELI5:

Rule of Law:

In a capital sentencing proceeding, the Eighth and Fourteenth Amendments are violated when jury instructions and a verdict form create a substantial probability that reasonable jurors may believe they are precluded from considering any mitigating evidence unless all twelve jurors unanimously agree on the existence of a particular mitigating circumstance.

Facts:

Ralph Mills was an inmate at the Maryland Correctional Institution.
Mills murdered his cellmate by repeatedly stabbing him with a homemade knife, or 'shank'.
During the sentencing phase of his trial, Mills' defense team presented evidence of potential mitigating circumstances.
This evidence included Mills' relative youth (age 20 at the time of the murder), a childhood diagnosis of 'minimal brain damage', and a history of behavioral issues for which state intervention had been sought since he was a child.

Procedural Posture:

Ralph Mills was convicted of first-degree murder by a jury in a Maryland state trial court.
During the sentencing phase, the same jury found the existence of one statutory aggravating circumstance.
Using a state-mandated verdict form, the jury marked 'no' next to every listed mitigating circumstance and returned a sentence of death.
Mills appealed his sentence to the Court of Appeals of Maryland, the state's highest court, arguing the verdict form and instructions were unconstitutionally mandatory.
The Maryland Court of Appeals affirmed the death sentence, holding that its sentencing scheme required unanimity for both the finding and rejection of mitigating circumstances, thus preserving its constitutionality.
The Supreme Court of the United States granted certiorari.

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Issue:

Does a capital sentencing scheme that may be interpreted by a reasonable jury as requiring a unanimous finding on the existence of a mitigating circumstance before any juror can consider it in the weighing process violate the Eighth and Fourteenth Amendments?

Opinions:

Majority - Justice Blackmun

Yes. A capital sentencing scheme violates the Eighth and Fourteenth Amendments if a reasonable jury could interpret it as precluding the consideration of mitigating evidence that is not unanimously found. The Constitution requires that the sentencer, which includes each individual juror, must be permitted to consider and give effect to any relevant mitigating evidence when deciding whether to impose the death penalty. The Maryland verdict form and instructions created a substantial risk that jurors believed they had to mark 'no' for any mitigating circumstance not unanimously found, thereby preventing individual jurors who did find that circumstance from weighing it against the aggravating factors. In death penalty cases, where reliability is paramount, any ambiguity that could lead to such a result must be resolved in favor of the accused, requiring the death sentence to be vacated.

Dissenting - Chief Justice Rehnquist

No. The capital sentencing scheme does not violate the Eighth and Fourteenth Amendments because a reasonable juror would have understood the instructions. The trial judge repeatedly emphasized that all findings, for or against a circumstance, must be unanimous. The instructions on the verdict form itself explicitly stated that a 'no' answer meant the jury unanimously found the circumstance was not proven. The majority's standard, requiring courts to rule out any 'substantial possibility' of misinterpretation, is an impossibly high and unworkable standard that departs from the established 'reasonable juror' test. There is no reason to believe the jury was confused, and the sentence should be affirmed.

Concurring - Justice Brennan

Yes. Justice Brennan joined the Court's opinion but wrote separately to reiterate his long-standing view that the death penalty is, in all circumstances, cruel and unusual punishment prohibited by the Eighth and Fourteenth Amendments. He would therefore not only vacate the sentence but also direct that the state be precluded from reimposing the death penalty on remand.

Concurring - Justice White

Yes. Justice White joined the Court's opinion, stating simply that he was persuaded the Court correctly resolved the issue of how reasonable jurors would have understood and applied their instructions.

Analysis:

This decision significantly clarifies the principle established in Lockett v. Ohio that the sentencer must be able to consider all mitigating evidence. Mills extends this by holding that individual jurors must be able to consider and give effect to mitigating evidence even if other jurors disagree. The ruling invalidates sentencing schemes that allow a single 'holdout' juror to prevent the rest of the jury from weighing a mitigating factor they find to be present. The focus shifts from a state appellate court's interpretation of its law to what a reasonable jury likely understood from the instructions and verdict form they were actually given, thereby strengthening protections against arbitrary imposition of the death penalty.

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