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A jury must be given an effective vehicle with which to weigh mitigating evidence so long as the defendant has met a low threshold for relevance, which is satisfied by evidence which tends logically to prove or disprove some fact or circumstance which a fact-finder could reasonably deem to have mitigating value.
During the sentencing phase of petitioner LaRoyce Lathair Smiths’ capital murder trial, the jury was instructed on two special issues: first, whether the killing was deliberate; and second, whether defendant posed a continuing danger to others. The nullification instruction told the jury to consider all the mitigating evidence and that if it believed that petitioner should not be sentenced to death, it had to answer one of the special issues "no." The mitigating evidence included petitioner’s low intelligence quotient (IQ) and placement in special-education classes. The jury answered “yes” to both special issues raised, and the petitioner was sentenced to death. The Texas Court of Criminal Appeals rejected the petitioner’s post-conviction relief, reasoning that the instruction either was irrelevant because the petitioner did not proffer "constitutionally significant" mitigation evidence.
Did the petitioner proffer constitutionally significant mitigation evidence that would warrant the grant of petitioner’s post-conviction relief?
The Court held that the petitioner’s evidence was relevant mitigating evidence under the Court’s precedents, and therefore, the Eighth Amendment required the trial court to empower the jury with a vehicle capable of giving effect to that evidence. According to the Court, the nullification instruction was constitutionally inadequate, for under the instruction, (a) the jury was required by law to answer a verdict form that made no mention whatsoever of mitigation evidence; (b) the burden of proof on the state was tied by law to findings of deliberateness and future dangerousness that had little, if anything, to do with the mitigation evidence presented; and (c) the jury was essentially instructed to return a false answer to a special issue in order to avoid a death sentence. The Court rejected a requirement that defendant had to prove a nexus between his limited mental abilities and the crime. Accordingly, the judgment of the Texas Court of Criminal Appeals was reversed, and the case was remanded for further proceedings.