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Law School Case Brief

Payne v. Tennessee - 501 U.S. 808, 111 S. Ct. 2597 (1991)

Rule:

A state may properly conclude that for the jury to assess meaningfully the defendant's moral culpability and blameworthiness, it should have before it at the sentencing phase evidence of the specific harm caused by the defendant. The state has a legitimate interest in counteracting the mitigating evidence that the defendant is entitled to put in, by reminding the sentencer that just as the murderer should be considered as an individual, so too the victim was an individual whose death represents a unique loss to society and in particular to his family.

Facts:

Defendant was accused of killing the victim and attempting to kill the victim’s son at the victims’ apartment. During the sentencing phase of the trial, the state presented the testimony of the victim’s mother and the prosecutor’s closing argument. The trial court convicted defendant of two counts of first-degree murder and one count of assault with intent to commit murder in the first degree, and sentenced him to death on each of the murder counts. The state supreme court affirmed the trial court’s judgment. Defendant appealed and argued that the admission of the testimony of the victim's mother and the prosecutor's closing argument violated his Eighth Amendment rights under the rules adopted in Booth and Gathers (791 SW2d 10). The Supreme Court of the United States affirmed the state supreme court’s decision.

Issue:

Did the admission of the testimony of the victim's mother and the prosecutor's closing argument violate defendant’s Eighth Amendment rights under the rules adopted in Booth and Gathers (791 SW2d 10)?

Answer:

No.

Conclusion:

If the state chose to permit the admission of victim impact evidence and prosecutorial argument on that subject, the Eighth Amendment presented no per se bar. A state could legitimately conclude that evidence about the victim and about the impact of the murder on the victim's family was relevant to the jury's decision as to whether or not the death penalty should be imposed. There was no reason to treat such evidence differently than other relevant evidence was treated. In so holding, the Supreme Court of the United States overruled its prior decisions in Booth v. Maryland and South Carolina v. Gathers (791 SW2d 10).

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