Law School Case Brief
Zant v. Stephens - 462 U.S. 862, 103 S. Ct. 2733 (1983)
The purpose of the statutory aggravating circumstances is to limit to a large degree, but not completely, the factfinder's discretion. Unless at least one of the ten statutory aggravating circumstances exists, the death penalty may not be imposed in any event. If there exists at least one statutory aggravating circumstance, the death penalty may be imposed but the factfinder has a discretion to decline to do so without giving any reason. In making the decision as to the penalty, the factfinder takes into consideration all circumstances before it from both the guilt-innocence and the sentence phases of the trial. These circumstances relate both to the offense and the defendant. The subsequent invalidation of one of several statutory aggravating circumstances does not automatically require reversal of a death penalty sentence where the State assures that a death sentence will be set aside if the invalidation of an aggravating circumstance makes the penalty arbitrary or capricious
On August 19, 1974, while respondent Zant was serving sentences for several burglary convictions and was also awaiting trial for escape, he again escaped from the Houston County Jail. In the next two days he committed two auto thefts, an armed robbery, and several burglaries. On August 21st, Roy Asbell interrupted respondent and an accomplice in the course of burglarizing the home of Asbell's son in Twiggs County. Respondent beat Asbell, robbed him, and, with the aid of the accomplice, drove him in his own vehicle a short distance into Bleckley County. There they killed Asbell by shooting him twice through the ear at point blank range. In January 1975, a jury in Bleckley County, Georgia, convicted respondent of the murder of Roy Asbell and sentenced him to death after finding three aggravating circumstances set forth in the Georgia death penalty statute. Thereafter, respondent sought review of his conviction at both the state and federal levels. The federal court of appeals held that respondent’s sentence was to be vacated because one of the aggravating circumstances had subsequently been held invalid. The State appealed this decision.
Should the respondent's death penalty sentence be vacated because one of the three statutory aggravating circumstances found by the jury was held to be invalid?
The Supreme Court of the United States reversed the judgment that concluded that defendant's death penalty was to be vacated, holding that subsequent invalidation of one of several aggravating circumstances did not require reversal where the purpose of the jury's finding such circumstances was to limit the discretion in imposing the death penalty and where state appellate review was to ensure that a death penalty would be set aside if it were arbitrary or capricious. The aggravating circumstance at issue related to defendant's prior criminal conduct but defendant's prior convictions would have been admissible nonetheless pursuant to state law and, therefore, the jury's verdict was not impermissibly swayed by evidence that would not otherwise have been presented to it. The Court held that the subsequent invalidation of one of several statutory aggravating circumstances does not automatically require reversal of the death penalty where the State assures that a death sentence will be set aside if the invalidation of an aggravating circumstance makes the penalty arbitrary or capricious
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