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The U.S. Supreme Court's review of habeas corpus petitioner's contention that the jury was improperly coerced requires that it consider the supplemental charge given by the trial court in its context and under all the circumstances.
At petitioner Lowenfield’s state-court trial on charges of killing five people, the jury returned guilty verdicts on three counts of first-degree murder, an essential statutory element of which, under the circumstances, was a finding of intent "to kill or inflict great bodily harm upon more than one person." At the penalty phase, in response to notes from the jury indicating difficulty in reaching a decision, the court twice polled the jury as to whether further deliberations would be helpful in reaching a verdict, a majority of the jurors answering affirmatively in each instance. After the second poll, the judge reiterated earlier instructions, declaring that he would impose a sentence of life imprisonment without benefit of probation, parole, or suspended sentence if the jurors were unable to reach a unanimous recommendation, and admonishing them to consult and consider each other's views with the objective of reaching a verdict, but not to surrender their own honest beliefs in doing so. Defense counsel did not object to either poll, to the manner in which they were conducted, or to the supplemental instruction. The jury then returned a verdict in 30 minutes, sentencing petitioner to death on all three first-degree murder counts upon finding the statutory aggravating circumstance of "knowingly creating a risk of death or great bodily harm to more than one person." After availing all of his state remedies, petitioner sought habeas corpus relief in federal court claiming that the jury was improperly coerced by the supplemental charge given by the state court. The lower courts denied the request for habeas corpus. Petitioner challenged the denial of his request for habeas corpus.
Under the circumstances, was the jury improperly coerced by the supplemental charge given by the state court, thereby entitling petitioner to a habeas corpus relief?
On review, the Court affirmed the lower courts holding that the jury was not coerced by the supplemental charge because the charge never required the jury to impermissibly reveal the nature or extent of its division on the merits of the verdict. Moreover, the Court held that the jury's finding of an aggravating circumstance that was an essential element of first-degree murder was inconsequential because the use of aggravating circumstance was simply a means of narrowing the class of persons eligible for death and a way of channeling the jury's discretion.