Capital Punishment: Summary of Supreme Court Decisions During the 1999-00 Term (CRS Report for Congress)
| Release Date |
July 6, 2000 |
| Report Number |
RS20620 |
| Report Type |
Report |
| Authors |
Paul S. Wallace, Jr., American Law Division |
| Source Agency |
Congressional Research Service |
Summary:
With the exception of the Supreme Court's ruling in Williams v. Taylor,
(1) the Court did not find any
serious reversible error in the lower courts' opinions reviewed during the 1999-2000 term that relate
to capital punishment. In Ramdass v. Angelone, (2)
it was decided that a habeas corpus petitioner
could not obtain relief from his death sentence on the ground that the state courts should have taken
a less technical approach to determining whether he was entitled to have the penalty phase jury
instructed that he would be ineligible for parole if the jury recommended a sentence of life
imprisonment. The state courts reasoned that because judgment had not been entered on one of the
petitioner's convictions, he did not have three "strikes" for purposes of the state's parole ineligibility
law. The Supreme Court affirmed the decision on June 12, 2000, reasoning that the entry of a
judgment of conviction upon a jury's guilty verdict in another case was not a forgone conclusion in
view of the possibility of post-trial motions. In Weeks v. Angelone, (3) the Court affirmed the Fourth
Circuit Court of Appeals denying the petitioner's appeal of a death penalty sentence and federal
habeas corpus petition, deciding that the jury instructions were constitutionally adequate.
In
Williams v. Taylor, (4) it was generally recognized that a defendant is
barred from proceeding with
federal habeas corpus claims which were not developed in the state habeas
corpus petition, however,
the Court allowed an evidentiary hearing on two claims due to the petitioner's diligence in pursuing
them.
1. Â 120 S. Ct. 1479 (2000).
2. Â Slip Op. No. 99-7000 (U.S. June 12, 2000).
3. Â 120 S. Ct. 727 (2000).
4. Â 120 S. Ct. 1479 (2000).
