Smith's Criminal Case Compendium
Smith's Criminal Case Compendium
Table of Contents
Smith's Criminal Case Compendium
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This compendium includes significant criminal cases by the U.S. Supreme Court & N.C. appellate courts, Nov. 2008 – Present. Selected 4th Circuit cases also are included.
Jessica Smith prepared case summaries Nov. 2008-June 4, 2019; later summaries are prepared by other School staff.
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In this habeas appeal, the petitioner was convicted of two murders in 1992 in Arizona state court. At that time, no requirement existed that the jury determine facts supporting an aggravating factor. At least one aggravating factor must be found to support a sentence of death under the Court’s...
The Court affirmed the decision below, rejecting the defendant’s argument that because of his unusual medical condition the State of Missouri’s lethal injection protocol is unconstitutional as applied to him.
For more detail about this decision, see my colleague blog post here:...
If a defendant with no memory of his crime rationally understands why the State seeks to execute him, the Eighth Amendment does not bar execution; if a defendant with dementia cannot rationally understand the reasons for his sentence, it does. What matters, explained the Court, is whether a...
In a per curiam opinion in this capital case, the Court held that the defendant has shown he is a person with intellectual disability. In 2015 a Texas appellate court held that the defendant did not have an intellectual disability and consequently was eligible for the death penalty. The Court...
In a per curiam decision in this capital murder case decided under the Antiterrorism and Effective Death Penalty Act of 1996, the Court held that the state court did not unreasonably apply the law when it determined that the defendant was competent to be executed. The defendant was sentenced to...
Vacating and remanding in this capital case, the Court held that a Texas court was wrong to fault a lower court for using a current definition of intellectual disability and by focusing on superseded standards and non-clinical factors for determining intellectual disability. Consulting current...
Where the State put the defendant’s future dangerousness at issue and acknowledged that his only alternative sentence to death was life imprisonment without parole, the Arizona court erred by concluding that the defendant had no right to inform the jury of his parole ineligibility. Under ...
The Eighth Amendment does not require courts to instruct capital sentencing juries that mitigating circumstances “need not be proved beyond a reasonable doubt.”
(1) The Eighth Amendment does not require courts to instruct capital sentencing juries that mitigating circumstances “need not be proved beyond a reasonable doubt.” (2) The Eighth Amendment was not violated by a joint capital sentencing proceeding for two defendants. The Court reasoned, in part...
The Court held Florida’s capital sentencing scheme unconstitutional. In this case, after a jury convicted the defendant of murder, a penalty-phase jury recommended that the judge impose a death sentence. Notwithstanding this recommendation, Florida law required the judge to hold a separate...
In this case, challenging Oklahoma’s lethal injection protocol, the Court affirmed the denial of the prisoner’s application for a preliminary injunction. The prisoners, all sentenced to death in Oklahoma, filed an action in federal court, arguing that Oklahoma’s method of execution violates the...
Because the Louisiana state court’s decision rejecting the defendant’s Atkins claim without affording him an evidentiary hearing was based on an unreasonable determination of the facts, the defendant was entitled to have his claim considered on the merits in federal court. After the...
The Court held unconstitutional a Florida law strictly defining intellectual disability for purposes of qualification for the death penalty. The Eighth and Fourteenth Amendments forbid the execution of persons with intellectual disability. Florida law defines intellectual disability to require...
In a per curiam opinion, the Court reversed a Sixth Circuit decision granting relief to a defendant on grounds that the jury instructions used in his capital trial ran afoul of Beck v. Alabama, 447 U.S. 625 (1980) (holding that the death penalty may not be imposed when the jury was not...
Distinguishing Mills v. Maryland, 486 U.S. 367 (1988), and holding that the penalty phase jury instructions and verdict forms were not unconstitutional. The defendant had asserted that the instructions improperly required the jury to consider in mitigation only those factors the jury...
The complex procedural history of this case, which involves motions for appropriate relief filed by three defendants under the Racial Justice Act and associated proceedings occurring over a years-long period of time when the RJA was amended and then repealed, is recounted in detail in the court’...
In a per curiam opinion, for the reasons stated in State v. Robinson, ___ N.C. ___, 846 S.E.2d 711 (2020) the court vacated the trial court’s order dismissing the defendant’s motion for appropriate relief filed pursuant to the Racial Justice Act and remanded the case for the...
In a per curiam opinion, for the reasons stated in State v. Robinson, ___ N.C. ___, 846 S.E.2d 711 (2020) the court vacated the trial court’s order dismissing the defendant’s motion for appropriate relief filed pursuant to the Racial Justice Act and remanded the case for the...
The defendant was convicted of first-degree murder and sentenced to death in 1994. The defendant filed a timely motion for appropriate relief pursuant to the RJA in 2010. After an evidentiary hearing, the trial court resentenced the defendant to life imprisonment without the possibility of...
The defendant was convicted of two counts of first-degree murder based on offenses committed in 2007. He was sentenced to death in 2010. That same year he filed a motion for appropriate relief under the North Carolina Racial Justice Act (RJA), but the trial court did not rule on it until...
The defendant was sentenced to death for first-degree murder in 1993. He filed a first motion for appropriate relief in 1997, which was denied in 2011. He filed a new MAR under the North Carolina Racial Justice Act (the RJA MAR) in 2010, amending it twice after the General Assembly amended...
(1) The court rejected the defendant’s argument that the trial court erred by denying his motion under the Racial Justice Act to prohibit the State from seeking the death penalty without holding an evidentiary hearing. Assuming arguendo that any version of the RJA applies to the defendant, the...
(1) In this capital case, the court rejected the defendant’s argument that the trial court deprived him of his state and federal constitutional right to a trial by a fair and impartial jury by prohibiting defense counsel from questioning prospective jurors concerning their ability to follow the...
In this capital case, before the supreme court on certiorari from an order of the trial court granting the defendant relief on his Racial Justice Act (RJA) motion for appropriate relief (MAR), the court vacated and remanded to the trial court. The supreme court determined that the trial court...
In this second RJA case the supreme court held that “the error recognized in this Court’s Order in [Robinson (summarized immediately above)], infected the trial court’s decision, including its use of issue preclusion, in these cases.” The court vacated the trial court’s order granting...
In this capital case, the court held that the cumulative effect of several errors at trial denied the defendant a fair trial; the court vacated the conviction and sentence and remanded for a new trial. Specifically, and as discussed in more detail in the summaries that follow, the trial court...
(1) In a case centered on the constitutionality of the State’s method of execution in capital cases, the Court held that the N.C. Council of State’s process for approving or disapproving the Department of Correction’s lethal injection protocol is not subject to the Administrative Procedure Act...
The trial court did not err by submitting the (f)(1) mitigating circumstance (no significant history of prior criminal activity) to the jury. The defendant’s prior record included: felony breaking and entering in 1999; felony larceny in 1998; driving under the influence in 1996; larceny in 1993...
The trial court erred by submitting the (f)(4) mitigating circumstance (defendant was an accomplice in or accessory to the capital felony committed by another person and his participation was relatively minor) to the jury where it was not supported by substantial evidence. However, in the...
The trial court did not err by failing to submit the G.S. 15A-2000(f)(1) (no significant history of prior criminal activity) mitigating circumstance. A forecast of evidence suggested that the defendant had violently abducted his former wife and forced her to engage in sexual activity.
(1) The trial court did not err by allowing the State’s challenge for cause of a prospective juror when the juror’s beliefs about the death penalty could not be pinned down. (2) The trial court did not err in denying the defendant’s motion to dismiss asserting that disproportionate numbers of...
The trial court did not err by instructing the jury to consider, over the defendant’s objection, the (f)(1) mitigating circumstance (no significant history of prior criminal activity). The defendant’s priors consisted of breaking and entering a motor vehicle (Class I felony) and several...
(1) The trial court did not err by failing to give a peremptory instruction on statutory mitigating circumstances when the evidence as to each was contested. (2) Although the trial court erred by failing to give a peremptory instruction on the non-statutory mitigating circumstance that the...
The trial judge has discretion regarding whether to submit the special issue of mental retardation to the jury in a bifurcated or unitary capital sentencing proceeding. The court held that in the case before it, the trial court did not abuse its discretion by denying a defense motion to...
The 2001 amendments to the capital sentencing statutes revoked the statutory mandate that provided the rationale for State v. Rorie, 348 N.C. 266 (1998) (holding that the trial court exceeded its authority to enforce Rule 24 by precluding the State from prosecuting a first-degree murder...
A judge who did not preside over the guilt phase of a capital trial had jurisdiction to preside over the penalty phase. The first judge had declared a mistrial as to the penalty phase after the defendant attacked one of his lawyers and both counsel were allowed to withdraw. The fact that the...
The random segregation of the entire jury pool so that it could be split among the defendant’s proceeding and other matters being handled at the courthouse that day was a preliminary administrative matter at which defendant did not have a right to be present.
The trial court erred by denying the defendant’s request to instruct the jury that a verdict finding the defendant mentally retarded would result in a sentence of life imprisonment without parole. The trial judge had given N.C.P.J.I.—Crim. 150.05, which states, in part, that “no defendant who is...
The trial judge properly denied a defense motion for imposition of a sentence of life imprisonment when polling revealed that the jury had returned a non-unanimous verdict after deliberations of just over 1 hour and 30 minutes. Under 15A-2000(b) “the only contingency in which a trial court...
The trial judge did not err by declining to give a peremptory instruction on a non-statutory mitigating circumstance that the defendant accepted responsibility for his criminal conduct. While the defendant admitted killing the victim and acknowledged that the killing was a terrible mistake, he...
The trial court did not commit plain error by submitting both the (e)(4) (murder committed to prevent arrest or effect escape) and (e)(8) (crime committed against law enforcement officer) aggravating circumstances. The (e)(4) aggravating circumstance focuses on the defendant’s subjective...
The trial court did not commit plain error by submitting both the (e)(4) (murder committed to prevent arrest or effect escape) and (e)(8) (crime committed against law enforcement officer) aggravating circumstances. The (e)(4) aggravating circumstance focuses on the defendant’s subjective...
The N.C. Medical Board’s position statement on physician participation in executions exceeds its authority under G.S. Chapter 90 because it contravenes the specific requirement of physician presence in G.S. 15-190.
The defendant was convicted of first-degree murder and sentenced to death. The defendant was eighteen years and five months old when he committed the murder. The court rejected the defendant’s argument that Roper v. Simmons, 543 U.S. 551 (2005) (Eighth Amendment prohibits execution of...
The defendant was convicted of first-degree murder and sentenced to death. Notwithstanding Roper v. Simmons, 543 U.S. 551 (2005) (Eighth Amendment prohibits execution of one who commits murder before eighteenth birthday), prior violent felonies committed when the defendant was...
The court remanded to the trial court this case challenging North Carolina’s drug protocol for lethal injections. The plaintiffs appealed a trial court order granting summary judgment to the defendants on the plaintiffs’ challenge to North Carolina’s previously used three-drug protocol for the...