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Law School Case Brief

Knight v. Florida - 528 U.S. 990, 120 S. Ct. 459 (1999)

Rule:

One cannot justify lengthy delays between conviction and sentence by reference to constitutional tradition.

Facts:

Knight was sentenced to death on April 21, 1975. By mid-1976, Knight had invoked all his direct appellate remedies and lost. By mid-1983, he had invoked all state collateral remedies and lost. But Knight had also filed a petition for habeas corpus in federal court; and in December 1988, the Federal Court of Appeals for the Eleventh Circuit found that Florida's death penalty sentencing procedure was constitutionally defective because it did not require the jury to take account of an unusually traumatic and abusive childhood as a potentially mitigating factor. In February 1996, the State held a new proceeding, and Knight was again sentenced to death. In November 1998, the Florida Supreme Court affirmed. Knight now sought certiorari, asking the United States Supreme Court to review his claim of inordinate delay -- 24 years and 6 months after he was first sentenced to death.

Issue:

Is the execution of prisoners who have spent nearly 20 years or more on death row considered as  "cruel and unusual punishment” under the Eighth Amendment?

Answer:

No.

Conclusion:

One cannot justify lengthy delays between conviction and sentence by reference to constitutional tradition. Consistency would seem to demand that those who accept our death penalty jurisprudence as a given also accept the lengthy delay between sentencing and execution as a necessary consequence. Ironically, the neoteric Eighth Amendment claim would further prolong collateral review by giving virtually every capital prisoner yet another ground on which to challenge and delay his execution. The claim might, in addition, provide reviewing courts a perverse incentive to give short shrift to a capital defendant's legitimate claims so as to avoid violating the Eighth Amendment right. The United States Supreme Court denied the petition for the writ of certiorari.

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