Saffle v. Parks
494 U.S. 484 (1990)
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Rule of Law:
A rule that would bar a capital sentencing jury from being instructed to avoid sympathy is a "new rule" under Teague v. Lane. Such a rule is not retroactively applicable on federal habeas corpus review because it was not dictated by precedent at the time the defendant's conviction became final and does not fall within Teague's narrow exceptions.
Facts:
- Robyn Leroy Parks shot and killed Abdullah Ibrahim, a gas station attendant, with a .45-caliber pistol.
- Parks murdered Ibrahim because he feared Ibrahim would report that Parks had used a stolen credit card to buy gasoline.
- Parks admitted the murder to a friend, and police obtained recordings of this confession.
- During the sentencing phase of his capital murder trial, Parks's father provided testimony about Parks’s difficult background and character as mitigating evidence.
- Parks's defense counsel argued in closing that Parks's youth, race, school experiences, and broken home were mitigating factors the jury should consider.
Procedural Posture:
- In 1978, an Oklahoma state court jury found Robyn Leroy Parks guilty of capital murder and, after a sentencing hearing, imposed the death penalty.
- During sentencing, the trial court instructed the jury to consider all mitigating evidence but to "avoid any influence of sympathy."
- The Oklahoma Court of Criminal Appeals, the state's highest court for criminal matters, affirmed Parks's conviction and sentence on direct appeal.
- The U.S. Supreme Court denied certiorari in 1983, at which point Parks's conviction and sentence became final.
- Parks filed a petition for a writ of habeas corpus in the U.S. District Court, arguing the anti-sympathy instruction was unconstitutional; the District Court denied relief.
- A three-judge panel of the U.S. Court of Appeals for the Tenth Circuit affirmed the District Court's denial.
- The Tenth Circuit, sitting en banc, reversed the panel's decision and held the instruction was unconstitutional, granting habeas relief.
- The U.S. Supreme Court granted certiorari to review the decision of the Tenth Circuit.
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Issue:
Does a rule prohibiting a jury instruction to avoid any influence of sympathy in the penalty phase of a capital trial constitute a "new rule" under Teague v. Lane, thereby barring its application on federal habeas corpus review?
Opinions:
Majority - Justice Kennedy
Yes. The principle that an anti-sympathy instruction violates the Eighth Amendment is a new rule within the meaning of Teague v. Lane and cannot be applied retroactively in a federal habeas proceeding. Precedent existing when Parks's conviction became final, specifically Lockett v. Ohio and Eddings v. Oklahoma, only established that a state cannot prevent a sentencer from considering relevant mitigating evidence. Those cases address what evidence must be considered, not how the jury must be guided in its consideration. A rule dictating the emotional framework for the jury's deliberation, such as allowing for sympathy, goes beyond what was compelled by Lockett and Eddings. Therefore, because the proposed rule was not dictated by precedent and does not meet either of Teague's exceptions for retroactive application, Parks is not entitled to relief.
Dissenting - Justice Brennan
No. The rule Parks seeks is not a new rule because it is directly compelled by the established precedent in Lockett v. Ohio and Eddings v. Oklahoma. The majority mischaracterizes Parks's claim; he does not assert a right to a sympathetic jury, but a right to a jury that is not precluded from considering his mitigating evidence. An instruction to avoid all sympathy risks confusing jurors into believing they must ignore relevant mitigating evidence about a defendant's background, as such evidence often naturally evokes sympathy. This preclusion of consideration is precisely what Lockett and Eddings forbid, meaning Parks's claim relies on an established rule, not a new one, and relief should be granted.
Analysis:
This decision significantly reinforces and expands the Teague v. Lane doctrine, making it more difficult for state prisoners to obtain federal habeas corpus relief. By defining a "new rule" as one that was not strictly "dictated" or "compelled" by prior precedent, the Court gives substantial deference to state court interpretations of constitutional law. This ruling narrows the avenue for collateral attacks on convictions, especially in capital cases, by preventing inmates from benefiting from constitutional developments that occur after their direct appeals are exhausted. It solidifies a high barrier for habeas petitioners and emphasizes finality in criminal convictions over the retroactive application of evolving legal standards.
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