Hildwin v. Florida | |
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Decided May 30, 1989 | |
Full case name | Paul C. Hildwin, petitioner v. Florida |
Docket no. | 88-6066 |
Citations | 490 U.S. 638 ( more ) 109 S.Ct. 2055, 104 L.Ed.2d 728 |
Holding | |
The Sixth Amendment does not require that the specific findings authorizing the imposition of the death sentence be made by a jury. | |
Court membership | |
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Case opinions | |
Per curiam | |
Dissent | Brennan |
Dissent | Marshall |
Laws applied | |
U.S. Const. amend. VI Spaziano v. Florida (1984) McMillan v. Pennsylvania (1986) | |
Overruled by | |
Hurst v. Florida (2016) |
Hildwin v. Florida, 490 U. S. 638 (1972), is a United States Supreme Court case which addresses the sixth amendment to the United States Constitution. It considers if imposition of the death penalty when no specific finding of aggravating factors was made by the jury. In a per curiam decision, the court ruled that there is no need for the jury to present specific findings when imposing the death penalty, as the judge is the one who decides the fact while the jury merely gives recommendations to the judge. [1]
The petitioner, Paul Hildwin, was convicted of first-degree murder, a capital offense, by the jury. During the sentencing, with only one factor needed to sentence him to death, the judge found four aggravating factors and sentenced him to death. However, the jury did not provide any aggravating factor in their advisory of verdict. [2]
The petitioner then appealed for the court to decide if the Florida capital sentencing scheme is in violation of the 6th amendment to the United States Constitution.
In a per curiam decision, the court upheld the Supreme Court of Florida's decision and held that there is no right under the sixth amendment to the United States Constitution that required there to be specific findings made by the jury to impose a death penalty. [3]
Both Justice Brennan and Marshall dissented and reiterated their view that the death penalty is cruel and unusual and pointed to their respective dissents in Gregg v. Georgia . [3]
This case was overturned in 2016 in the Supreme Court ruling Hurst v. Florida . [4] [5] [6]
The defendant, Paul Hildwin, was released in 2020 after 35 years following DNA testing exonerated him of the crime. [7] [8] [9]
Furman v. Georgia, 408 U.S. 238 (1972), was a landmark criminal case in which the United States Supreme Court invalidated all then existing legal constructions for the death penalty in the United States. It was 5–4 decision, with each member of the majority writing a separate opinion. Following Furman, in order to reinstate the death penalty, states had to at least remove arbitrary and discriminatory effects in order to satisfy the Eighth Amendment to the U.S. Constitution.
Apprendi v. New Jersey, 530 U.S. 466 (2000), is a landmark United States Supreme Court decision with regard to aggravating factors in crimes. The Court ruled that the Sixth Amendment right to a jury trial, incorporated against the states through the Fourteenth Amendment, prohibited judges from enhancing criminal sentences beyond statutory maxima based on facts other than those decided by the jury beyond a reasonable doubt. The decision has been a cornerstone in the modern resurgence in jury trial rights. As Justice Scalia noted in his concurring opinion, the jury-trial right "has never been efficient; but it has always been free."
Gregg v. Georgia, Proffitt v. Florida, Jurek v. Texas, Woodson v. North Carolina, and Roberts v. Louisiana, 428 U.S. 153 (1976), is a landmark decision of the U.S. Supreme Court. It reaffirmed the Court's acceptance of the use of the death penalty in the United States, upholding, in particular, the death sentence imposed on Troy Leon Gregg. The case is referred to by a leading scholar as the July 2 Cases, and elsewhere referred to by the lead case Gregg. The court set forth the two main features that capital sentencing procedures must employ in order to comply with the Eighth Amendment ban on "cruel and unusual punishments". The decision essentially ended the de facto moratorium on the death penalty imposed by the Court in its 1972 decision in Furman v. Georgia 408 U.S. 238 (1972).
Ring v. Arizona, 536 U.S. 584 (2002), was a case in which the United States Supreme Court applied the rule of Apprendi v. New Jersey to capital sentencing schemes, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty. Ring overruled a portion of Walton v. Arizona, which had rejected that contention.
McCleskey v. Kemp, 481 U.S. 279 (1987), is a United States Supreme Court case, in which the death sentence of Warren McCleskey for armed robbery and murder was upheld. The Court said the "racially disproportionate impact" in the Georgia death penalty indicated by a comprehensive scientific study was not enough to mitigate a death penalty determination without showing a "racially discriminatory purpose." McCleskey has been described as the “most far-reaching post-Gregg challenge to capital sentencing.”
Kansas v. Marsh, 548 U.S. 163 (2006), is a United States Supreme Court case in which the Court held that a Kansas death penalty statute was consistent with the United States Constitution. The statute in question provided for a death sentence when the aggravating factors and mitigating factors were of equal weight.
Walton v. Arizona, 497 U.S. 639 (1990), was a United States Supreme Court case that upheld two important aspects of the capital sentencing scheme in Arizona—judicial sentencing and the aggravating factor "especially heinous, cruel, or depraved"—as not unconstitutionally vague. The Court overruled the first of these holdings in Ring v. Arizona, 536 U.S. 584 (2002). The second of these holdings has yet to be overturned.
Stanford v. Kentucky, 492 U.S. 361 (1989), was a United States Supreme Court case that sanctioned the imposition of the death penalty on offenders who were at least 16 years of age at the time of the crime. This decision came one year after Thompson v. Oklahoma, in which the Court had held that a 15-year-old offender could not be executed because to do so would constitute cruel and unusual punishment. In 2003, the Governor of Kentucky Paul E. Patton commuted the death sentence of Kevin Stanford, an action followed by the Supreme Court two years later in Roper v. Simmons overruling Stanford and holding that all juvenile offenders are exempt from the death penalty.
Whitus v. Georgia, 385 U.S. 545 (1967), found in favor of the petitioner (Whitus), who had been convicted for murder, and as such reversed their convictions. This was due to the Georgia jury selection policies, in which it was alleged racial discrimination had occurred.
Witherspoon v. Illinois, 391 U.S. 510 (1968), was a U.S. Supreme Court case where the court ruled that a state statute providing the state unlimited challenge for cause of jurors who might have any objection to the death penalty gave too much bias in favor of the prosecution.
Baze v. Rees, 553 U.S. 35 (2008), is a decision by the United States Supreme Court, which upheld the constitutionality of a particular method of lethal injection used for capital punishment.
Tennard v. Dretke, 542 U.S. 274 (2004), was a United States Supreme Court case in which the court was asked whether evidence of the defendant's low IQ in a death penalty trial had been adequately presented to the jury for full consideration in the penalty phase of his trial. The Supreme Court held that not considering a defendant's low IQ would breach his Eighth Amendment rights and constitute a cruel and unusual punishment.
Lockett v. Ohio, 438 U.S. 586 (1978), is a United States Supreme Court case in which the Court held that sentencing authorities must have the discretion to consider at least some mitigating factors, rather than being limited to a specific list of factors.
The Supreme Court of the United States handed down nineteen per curiam opinions during its 2009 term, which began on October 5, 2009, and concluded October 3, 2010.
Spaziano v. Florida was two United States Supreme Court cases dealing with the imposition of the death penalty. In the first case, 454 U.S. 1037 (1981), the Supreme Court, with two dissents, refused Spaziano's petition for certiorari. However, the Florida Supreme Court would reverse Spaziano's death sentence based on the judge's receipt of a confidential report which was not received by either party. On remand, the judge reimposed the death penalty and the Florida Supreme Court upheld the sentence. In the second case, 468 U.S. 447 (1984), the Court heard Spaziano's appeal of his death sentence.
Deck v. Missouri, 544 U.S. 622 (2005), was a United States Supreme Court case that dealt with the constitutionality of shackling a prisoner during the sentencing phase of a trial. In a 7–2 opinion delivered by Justice Breyer, the court held that it is against due process, a right prescribed by the 5th and 14th Amendments, to shackle a defendant in the sentencing portion of a trial unless the shackling relates to a specific defendant and certain state interests.
Dawson v. Delaware, 503 U.S. 159 (1992), was a United States Supreme Court decision that ruled that a person's rights of association and due process, as granted under the First Amendment and Fourteenth Amendment of the United States Constitution, cannot be infringed upon if such an association has no bearing on the case at hand.
Hurst v. Florida, 577 U.S. 92 (2016), was a United States Supreme Court case in which the Court, in an 8–1 ruling, applied the rule of Ring v. Arizona to the Florida capital sentencing scheme, holding that the Sixth Amendment requires a jury to find the aggravating factors necessary for imposing the death penalty. In Florida, under a 2013 statute, the jury made recommendations but the judge decided the facts.
Lockhart v. Fretwell, 506 U.S. 364 (1993), is a decision of the United States Supreme Court which held that failure to make an objection under Collins v. Lockhart did not constitute undue prejudice required by Strickland v. Washington, because the error did not cause a fundamentally unfair trial, as opposed to merely a different outcome of the case.
Moore v. Texas, 137 S. Ct. 1039 (2017), is a United States Supreme Court decision about the death penalty and intellectual disability. The court held that contemporary clinical standards determine what an intellectual disability is, and held that even milder forms of intellectual disability may bar a person from being sentenced to death due to the Eighth Amendment's prohibition against cruel and unusual punishment. The case clarified two earlier cases, Atkins v. Virginia (2002) and Hall v. Florida (2014).