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Law School Case Brief

Eddings v. Oklahoma - 455 U.S. 104, 102 S. Ct. 869 (1982)

Rule:

The Eighth and Fourteenth Amendments require that the sentencer not be precluded from considering, as a mitigating factor, any aspect of a defendant's character or record and any of the circumstances of the offense that the defendant proffers as a basis for a sentence less than death. The sentencer must be free to give independent mitigating weight to aspects of the defendant's character and record and to circumstances of the offense proffered in mitigation.

Facts:

Defendant Monty Lee Eddings, together with several younger companions, ran away from their Missouri homes. After Eddings momentarily lost control of the car, he was signaled to pull over by Officer Crabtree of the Oklahoma Highway Patrol. Eddings did so, and when the officer approached the car, Eddings stuck a loaded shotgun out of the window and fired, killing the officer. Because Eddings was a juvenile, the State filed a motion to have him certified to stand trial as an adult, which was granted. Eddings was later found guilty of murder in the first degree by an Oklahoma state court upon his plea of nolo contendere. Oklahoma's death penalty statute provided that in the sentencing proceeding, evidence could be presented as to "any mitigating circumstances" or as to any of certain enumerated aggravating circumstances. At the sentencing hearing, the state alleged three of the aggravating circumstances, and, in mitigation, Eddings presented substantial evidence of a turbulent family history, of beatings by a harsh father, and of severe emotional disturbance. The trial judge found that the State had proved each of the three alleged aggravating circumstances beyond a reasonable doubt and considered the Eddings' youth as a mitigating circumstance, but found, as a matter of law, that he could not consider in mitigation the circumstances of Eddings' unhappy upbringing and emotional disturbance. Eddings was sentenced to death. On appeal, the Court of Criminal Appeals of Oklahoma affirmed the sentence of death, finding that each of the aggravating circumstances alleged by the State had been present and agreed with the trial court that only the fact of Eddings' youth was properly considered as a mitigating circumstance. Eddings was granted a writ of certiorari In this current petition, Eddings argued that his death sentence violated the Eighth and Fourteenth Amendments because mitigating factors were not considered.

Issue:

By failing to consider mitigating factors other than Eddings' youth, did the lower courts violate Eddings' Eight and Fourteenth Amendment rights, thereby warranting the reversal of the imposition of death penalty?

Answer:

Yes.

Conclusion:

The Supreme Court of the United States reversed that part of the judgment of the state court of criminal appeals that sustained the death penalty imposed against Eddings. The Court held that the Eighth and Fourteenth Amendments required that the sentencer not be precluded from considering, as a mitigating factor, any aspect of a defendant's character or record and any of the circumstances of the offense that the defendant proffered as a basis for a sentence less than death. In the present case, the Court concluded that the lower courts both erred in limiting their review of mitigating factors only to Eddings' age. The Court noted that Eddings was an emotionally disturbed youth with a violent family background. While these circumstances did not suggest an absence of responsibility for the crime, they had to be considered in sentencing. As such, the Court concluded that the death sentence must be vacated as it was imposed without the type of individualized consideration of mitigating factors required by the Eighth and Fourteenth Amendments in capital cases. On remand, the Court instructed, the state courts were to consider all relevant mitigating evidence and weigh it against the evidence of the aggravating circumstances.
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