Morgan v. Illinois | |
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Argued January 21, 1992 Decided June 15, 1992 | |
Full case name | Derrick Morgan v. State of Illinois |
Citations | 504 U.S. 719 ( more ) 112 S. Ct. 2222; 119 L. Ed. 2d 492; 1992 U.S. LEXIS 3548; 60 U.S.L.W. 4541; 92 Cal. Daily Op. Service 5037; 92 Daily Journal DAR 7962; 6 Fla. L. Weekly Fed. S 421 |
Case history | |
Prior | Certiorari to the Supreme Court of Illinois |
Holding | |
A defendant facing the death penalty may challenge for cause a prospective juror who would automatically vote to impose the death penalty in every case. | |
Court membership | |
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Case opinions | |
Majority | White, joined by Blackmun, Stevens, O'Connor, Kennedy, Souter |
Dissent | Scalia, joined by Rehnquist, Thomas |
Laws applied | |
U.S. Const. amend. VI, Due Process Clause |
Morgan v. Illinois, 504 U.S. 719 (1992), is a case decided by the United States Supreme Court. The case established the right of defendants to challenge for cause any juror that would automatically impose the death penalty in all capital cases.
In an elaboration of the Witherspoon v. Illinois (1968) doctrine, the Rehnquist Court considered challenges to the selection of jurors who would automatically vote to impose the death penalty on a defendant convicted of a capital offense. In a 6–3 decision, Justice White wrote for the majority that a defendant facing the death penalty may challenge for cause a prospective juror who would automatically vote to impose the death penalty in every case. Just as a juror who is unalterably opposed to the imposition of the death penalty must be excluded because he or she cannot conscientiously fulfill the oath to follow the law and the instructions to the jury pursuant thereto, so should one who would automatically vote to impose the death penalty be excluded for the same reason. Such a juror, he emphasized, would lack the qualities of impartiality and indifference required by due process. Furthermore, Justice White noted, jurors who would automatically vote to impose the death penalty would not "in good faith ... consider evidence of aggravating and mitigating circumstances" as may be required by law and included in jury instructions. [1]
A jury is a sworn body of people (jurors) convened to hear evidence and render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment.
A hung jury, also called a deadlocked jury, is a judicial jury that cannot agree upon a verdict after extended deliberation and is unable to reach the required unanimity or supermajority. Hung juries usually result in the case being tried again.
Batson v. Kentucky, 476 U.S. 79 (1986), was a landmark decision of the United States Supreme Court ruling that a prosecutor's use of a peremptory challenge in a criminal case—the dismissal of jurors without stating a valid cause for doing so—may not be used to exclude jurors based solely on their race. The Court ruled that this practice violated the Equal Protection Clause of the Fourteenth Amendment. The case gave rise to the term Batson challenge, an objection to a peremptory challenge based on the standard established by the Supreme Court's decision in this case. Subsequent jurisprudence has resulted in the extension of Batson to civil cases and cases where jurors are excluded on the basis of sex.
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 set of cases 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).
A death-qualified jury is a jury in a criminal law case in the United States in which the death penalty is a prospective sentence. Such a jury will be composed of jurors who:
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.”
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.
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.
Uttecht v. Brown, 551 U.S. 1 (2007), was a case dealing with jury selection in capital cases in which the Supreme Court of the United States held that appeals courts must defer to a trial judge’s decision on whether a potential juror would be able to overcome demur about capital punishment and be open to voting to impose a death sentence.
Adams v. Texas, 448 U.S. 38 (1980), was a United States Supreme Court case in which the Court held on an 8–1 vote that, consistent with its prior opinion in Witherspoon v. Illinois, a Texas requirement that jurors swear an oath that the mandatory imposition of a death sentence would not interfere with their consideration of factual matters such as guilt or innocence during a trial was unconstitutional.
Apodaca v. Oregon, 406 U.S. 404 (1972), was a United States Supreme Court case in which the Court held that state juries may convict a defendant by a less-than-unanimous verdict in a felony criminal case. The four-justice plurality opinion of the court, written by Justice White, affirmed the judgment of the Oregon Court of Appeals and held that there was no constitutional right to a unanimous verdict. Although federal law requires federal juries to reach criminal verdicts unanimously, the Court held Oregon's practice did not violate the Sixth Amendment right to trial by jury and so allowed it to continue. In Johnson v. Louisiana, a case decided on the same day, the Court held that Louisiana's similar practice of allowing criminal convictions by a jury vote of 9–3 did not violate due process or equal protection under the Fourteenth Amendment.
J. E. B. v. Alabama ex rel. T. B., 511 U.S. 127 (1994), was a landmark decision of the Supreme Court of the United States holding that peremptory challenges based solely on a prospective juror's sex are unconstitutional. J.E.B. extended the court's existing precedent in Batson v. Kentucky (1986), which found race-based peremptory challenges in criminal trials unconstitutional, and Edmonson v. Leesville Concrete Company (1991), which extended that principle to civil trials. As in Batson, the court found that sex-based challenges violate the Equal Protection Clause.
Lowenfield v. Phelps, 484 U.S. 231 (1988),is a United States Supreme Court case. The Court held that the two jury polls and the supplemental charge did not unlawfully pressure the jury to give a death sentence. The Court also stated that the death sentence does not violate the Eighth Amendment. This is simply because the single statutory "aggravating circumstance" found by the jury duplicates an element of the underlying offense of first-degree murder.
Teague v. Lane, 489 U.S. 288 (1989), was a United States Supreme Court case dealing with the application of newly announced rules of law in habeas corpus proceedings. This case addresses the Federal Court's threshold standard of deciding whether Constitutional claims will be heard. Application of the "Teague test" at the most basic level limits habeas corpus.
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.
Wainwright vs. Witt, 469 U.S. 412 (1985), was a U.S. Supreme Court case concerning a criminal defendant, Johnny Paul Witt, who argued that his Sixth and Fourteenth Amendment rights were violated when he was sentenced to death for first degree murder by the state of Florida. He argued that the trial court had unconstitutionally hand-picked a jury during the voir dire process. This was because certain people were excused from the jury because they admitted pre-trial, that their decision of guilty or not guilty toward capital punishment would be swayed due to personal or religious beliefs.
The United States Constitution contains several provisions related to criminal sentencing.
Kansas v. Carr, 577 U.S. ___ (2016), was a case in which the Supreme Court of the United States clarified several procedures for sentencing defendants in capital cases. Specifically, the Court held that judges are not required to affirmatively instruct juries about the burden of proof for establishing mitigating evidence, and that joint trials of capital defendants "are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events". This case included the last majority opinion written by Justice Antonin Scalia before his death in February 2016.
Powers v. Ohio, 499 U.S. 400 (1991), was a United States Supreme Court case that re-examined the Batson Challenge. Established by Batson v. Kentucky, 476 U.S. 79 (1986), the Batson Challenge prohibits jury selectors from using peremptory challenges on the basis of race, ethnicity, gender, and sex. Powers expanded the jurisdictions of this principle, allowing all parties within a case, defendants especially, to question preemptory challenges during a jury selection, regardless of race. This holding was protected under the Equal Protection Clause of the Fourteenth Amendment.
Johnson v. Louisiana, 406 U. S. 356 (1972), was a court case in the U.S. Supreme Court involving the Due Process Clause and Equal Protection Clause of the Fourteenth Amendment to the United States Constitution. The U.S. Supreme Court ruled that the Louisiana law that allowed less-than unanimous jury verdicts to convict persons charged with a felony, does not violate the Due Process clause. This case was argued on a similar basis as Apodaca v. Oregon.