Case Summaries - U.S. Supreme Court (Feb. 25, 2020)

This post summarizes cases from the U.S. Supreme Court from February 25, 2020. Appellate reweighing of aggravating and mitigating factors was permissible; death sentence affirmed by divided Supreme Court McKinney v. Arizona, ___ S. Ct. ___, 2020 WL 889190 (Kavanaugh, J.). 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 precedents. In the petitioner’s case, the trial court found factors in aggravation for both murders and imposed death. In federal habeas proceedings 20 years later, the Ninth Circuit found that the trial court improperly ignored mitigation evidence in violation of Eddings v. Oklahoma, 455 U.S. 104 (1982) (reversible error for trial court to ignore relevant mitigation evidence at capital sentencing). The case returned to the Arizona Supreme Court, where the petitioner argued for a new sentencing hearing before a jury. The Arizona Supreme Court rejected this argument, pointing to Clemons v. Mississippi, 494 U.S. 738 (1990). Clemons allows a state appellate court to reweigh aggravating and mitigating factors in a death case following reversal for use of an improper aggravating factor (instead of a jury weighing those factors). The Arizona Supreme Court reweighed the sentencing factors in the case and again imposed death. The petitioner appealed to the U.S. Supreme Court, arguing that a jury should have made that determination. A [...]