Eddings v. Oklahoma

Supreme Court of the United States · 1982 · Federal Courts

Federal CourtsCapital PunishmentSentencingEighth Amendmentdeath penaltymitigating evidencecapital sentencingindividualized sentencing

Facts

Eddings was 16 years old when, after running away from home and being stopped by an Oklahoma highway patrol officer, he shot and killed the officer with a loaded shotgun. At the capital sentencing hearing, the State proved three aggravating circumstances, while Eddings presented substantial mitigating evidence about his turbulent family history, severe physical discipline by his father, emotional disturbance, and below-age mental and emotional development. The trial judge gave great weight to Eddings' youth but stated that, in following the law, he could not consider the young man's violent background, and imposed death. The Oklahoma Court of Criminal Appeals likewise treated Eddings' family history and emotional disorder as not mitigating because they did not excuse his behavior under the state's test of criminal responsibility.

Issue

Whether the Eighth and Fourteenth Amendments permit a capital sentencer to refuse, as a matter of law, to consider relevant mitigating evidence such as a 16-year-old defendant's troubled family history and emotional disturbance when deciding whether to impose the death penalty.

Rule

Under the Eighth and Fourteenth Amendments, the sentencer in a capital case must not be precluded from considering, as mitigating, any aspect of the defendant's character or record and any circumstance of the offense that the defendant proffers as a basis for a sentence less than death. A sentencer may determine the weight of relevant mitigating evidence, but may not give it no weight by excluding it from consideration as a matter of law.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a capital sentencing hearing in Phoenix, 19-year-old Daniel Morrow presents evidence that he suffered repeated childhood abuse, severe neglect, and long-term depression. The judge states that because Daniel was legally sane and understood right from wrong, those circumstances are not legally mitigating and will not be considered in deciding between death and life imprisonment.

Under the governing constitutional rule, is the judge's approach permissible?

Explanation. The controlling rule is that in a capital case the sentencer must be permitted to consider any relevant mitigating evidence offered as a basis for a sentence less than death. The sentencer may decide the weight of that evidence, but may not exclude it from consideration as a matter of law because it does not establish a legal excuse or negate criminal responsibility. That is exactly what the judge did here, so the approach is unconstitutional. (Derived from Eddings v. Oklahoma (1982).)