Smith v. Texas

Supreme Court of the United States
2004 U.S. LEXIS 7668, 543 U.S. 37, 160 L. Ed. 2d 303 (2004)

ELI5:

Rule of Law:

Under the Eighth Amendment, a capital sentencing jury instruction is unconstitutional if it requires jurors to give effect to mitigating evidence by answering special issue questions on a verdict form in a manner contrary to the evidence (i.e., by nullifying a factually correct answer). Such an instruction fails to provide the jury with an adequate vehicle to express a reasoned moral response to all relevant evidence.

Facts:

LaRoyce Lathair Smith and several friends asked to be let into a Taco Bell where Smith was a former employee.
Two employees, who recognized Smith, let him into the restaurant after it had closed.
Smith then announced he was robbing the restaurant and told his former co-workers to leave.
When one of the co-workers did not leave, Smith pistol-whipped her and shot her in the back, resulting in her death.
During the punishment phase of his trial, Smith presented mitigating evidence.
This evidence included a low IQ (78), learning disabilities, placement in special education classes, and a troubled childhood with a drug-addicted father involved in criminal activity.
Smith was 19 years old at the time of the offense.

Procedural Posture:

LaRoyce Lathair Smith was convicted of capital murder and sentenced to death by a jury in a Texas state trial court.
On direct appeal, the Texas Court of Criminal Appeals (Texas's highest court for criminal cases) affirmed Smith's conviction and sentence.
The U.S. Supreme Court denied Smith's petition for a writ of certiorari.
Smith later filed a state writ of habeas corpus, arguing that his jury instructions were unconstitutional under the U.S. Supreme Court's decision in Penry II.
The Texas Court of Criminal Appeals denied Smith's application for postconviction relief on the merits.
The U.S. Supreme Court granted Smith's petition for a writ of certiorari to review the decision of the Texas Court of Criminal Appeals.

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Issue:

Does a capital sentencing instruction that requires a jury to give effect to mitigating evidence by answering special issue questions falsely (i.e., 'No' when the evidence supports 'Yes') violate the Eighth Amendment?

Opinions:

Majority - Per Curiam

Yes. A jury instruction that requires jurors to nullify their truthful answers to special issues to give effect to mitigating evidence violates the Eighth Amendment. The instruction creates a logical and ethical dilemma, forcing jurors to choose between following their oath to render a true verdict based on the evidence for the special issues and the instruction to give effect to mitigating circumstances by answering those same issues falsely. Citing its precedent in Penry v. Johnson (Penry II), the Court held that this mechanism inserts an element of capriciousness into the sentencing decision and does not provide an adequate vehicle for the jury to make a reasoned moral response to the defendant's mitigating evidence. The Court also rejected the Texas court's use of a 'constitutional relevance' or 'nexus' test for mitigating evidence, holding that Smith's evidence of a low IQ and troubled childhood easily met the low threshold for relevance.

Dissenting - Justice Scalia

No. The judgment of the Texas Court of Criminal Appeals should be affirmed. The dissent cites Justice Scalia's prior concurrence in Walton v. Arizona, which argued that the Eighth Amendment does not require individualized sentencing in capital cases and that the foundational case requiring it (Penry I) was wrongly decided.

Analysis:

This decision reinforces and clarifies the Court's holding in Penry II, solidifying the unconstitutionality of 'nullification instructions' in capital sentencing schemes. It strongly rejects attempts by lower courts to apply screening tests or nexus requirements that would limit the scope of what a jury may consider as mitigating evidence, thereby broadening the protection for capital defendants. The case serves as a clear directive that any vehicle for considering mitigating evidence must be straightforward and must not place jurors in an ethical bind or require them to violate their oath, ensuring the sentencing process is based on a reasoned moral response rather than confusion or caprice.

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