Lynch v. Arizona

Lynch v. Arizona

Opinion

 [*613]   [**1818]   PER CURIAM.

Under Simmons v. South Carolina, 512 U. S. 154, 114 S. Ct. 2187, 129 L. Ed. 2d 133 (1994), and its progeny, “where a capital defendant’s future dangerousness is at issue, and the only sentencing alternative to death available to the jury is life imprisonment without possibility of parole,” the Due Process Clause “entitles the defendant ‘to inform the jury of [his] parole ineligibility, either  [*614]  by a jury instruction or in arguments by counsel.’” Shafer v. South Carolina, 532 U. S. 36, 39, 121 S. Ct. 1263, 149 L. Ed. 2d 178  [***101]  (2001) (quoting Ramdass v. Angelone, 530 U. S. 156, 165, 120 S. Ct. 2113, 147 L. Ed. 2d 125 (2000) (plurality opinion)). In the decision below, the Arizona Supreme Court found that the  [**1819]  State had put petitioner Shawn Patrick Lynch’s future dangerousness at issue during his capital sentencing proceeding and acknowledged that Lynch’s only alternative sentence to death was life imprisonment without parole. 238 Ariz. 84, 103, 357 P. 3d 119, 138 (2015). But the court nonetheless concluded that Lynch had no right to inform the jury of his parole ineligibility. Ibid. The judgment is reversed.

A jury convicted Lynch of first-degree murder, kidnapping, armed robbery, and burglary for the 2001 killing of James Panzarella. The State sought the death penalty. Before Lynch’s penalty phase trial began, Arizona moved to prevent his counsel from informing [****2]  the jury that the only alternative sentence to death was life without the possibility of parole. App. K to Pet. for Cert. The court granted the motion.

Lynch’s first penalty phase jury failed to reach a unanimous verdict. A second jury was convened and sentenced Lynch to death. On appeal, the Arizona Supreme Court vacated the sentence because the jury instructions improperly described Arizona law. The court did not address Lynch’s alternative argument that the trial court had violated Simmons. On remand, a third penalty phase jury sentenced Lynch to death.

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