Brief Fact Summary. The Petitioner, Warren McCleskey (Petitioner), a black man, was convicted of the murder of a white police officer during the course of a robbery. In the post-conviction sentencing hearing, the jury recommended the death penalty after it found beyond a reasonable doubt the existence of two statutory aggravating circumstances and no mitigating factors. The judge followed the recommendation and sentenced the Petitioner to death. On appeal, the state supreme court affirmed the conviction and the sentence.
Synopsis of Rule of Law. The United States Constitution (Constitution) does not require that a state eliminate any demonstrable disparity that correlates with a potentially irrelevant factor in order to operate a criminal justice system that includes capital punishment.
Issue. Whether a complex statistical study that indicates a risk that racial considerations enter into capital sentencing determinations proves that the Petitioner’s capital sentence is unconstitutional under the Eighth or Fourteenth Amendment of the Constitution?
Held. The court examined, separately, the Petitioner’s claims that the capital sentencing structure violated both his Eighth and Fourteenth Amendment rights.
The Petitioner’s claim as to the violation of his Fourteenth Amendment constitutional rights must fail. The court found that the Baldus Study was clearly insufficient to support an inference that any of the decision-makers in the Petitioner’s case acted with a discriminatory purpose.
The court also rejected petitioner’s claim that his Eighth Amendment constitutional rights were violated. The court found that the inherent safeguards that are built into the jury system served to nearly eliminate every discrepancy that appears to correlate with race.
This presumption applies only if the sentencing procedures focus discretion on the particularized nature of the crime and the particularized characteristics of the individual defendant.View Full Point of Law