Simmons v. South Carolina - 512 U.S. 154, 114 S. Ct. 2187 (1994)

Rule:

Because truthful information of parole ineligibility allows the defendant to "deny or explain" the showing of future dangerousness, due process plainly requires that he be allowed to bring it to the jury's attention by way of argument by defense counsel or an instruction from the court.

Facts:

Petitioner Jonathan Dale Simmons beat to death an elderly woman. During the penalty phase of petitioner's South Carolina trial, the State argued that his future dangerousness was a factor for the jury to consider when deciding whether to sentence him to death or life imprisonment for the murder of an elderly woman. In rebuttal, petitioner presented evidence that his future dangerousness was limited to elderly women and thus there was no reason to expect violent acts from him in prison. However, the court refused to give the jury his proposed instruction that under state law he was ineligible for parole. When asked by the jury whether life imprisonment carried with it the possibility of parole, the court instructed the jury not to consider parole in reaching its verdict and that the terms life imprisonment and death sentence were to be understood to have their plain and ordinary meaning. The jury returned a death sentence. On appeal, the State Supreme Court concluded that regardless of whether a trial court's refusal to inform a sentencing jury about a defendant's parole ineligibility might ever be error, the instruction given to petitioner's jury satisfied in substance his request for a charge on such ineligibility. Petitioner sought further review, contending that the trial court's refusal to provide the jury accurate information regarding his parole eligibility violated the due process clause of the Constitution's Fourteenth Amendment.

Issue:

Was the trial court’s refusal to provide the jury accurate information regarding petitioner’s parole eligibility violative of the due process clause of the Constitution's Fourteenth Amendment?

Answer:

Yes.

Conclusion:

The Court held that the trial court violated due process by refusing to allow the capital sentencing jury to be informed that the petitioner was ineligible for parole under state law. According to the Court, in the penalty phase of a state capital trial, where the defendant's future dangerousness was at issue, and where state law prohibited the defendant's release on parole, the Fourteenth Amendment's due process clause required that the sentencing jury be informed that the defendant was ineligible for parole under state law. In the case at hand, the trial court's instructions in response to the jury's note did not satisfy due process, as the instructions were confusing and frustrating to the jury, in view of circumstances including the misunderstanding that reasonable jurors may have about the way in which any particular state defined life imprisonment, the arguments by both the prosecution and the defense relating to the petitioner’s future dangerousness, and the relevance of the petitioner's parole ineligibility to the jury's formidable sentencing task.