Supreme Court of the United States
Zant v. Stephens
June 22, 1983462 U.S. 862
Summary
The Court reversed the judgment requiring vacation of respondent's death sentence. It held that Georgia's capital-sentencing scheme constitutionally narrows death-penalty eligibility through statutory aggravating circumstances while leaving the ultimate selection decision to the sentencer, and that the jury's express findings of two valid aggravating circumstances supported the sentence. The later invalidation of a third circumstance did not require reversal because the underlying evidence was admissible and the invalid circumstance did not involve constitutionally protected conduct or otherwise create a constitutional defect in the sentencing process.
Holding
- Constitutionality of Georgia's capital-sentencing scheme. Georgia's capital-sentencing scheme is constitutional as applied because statutory aggravating circumstances narrow the class of murder defendants eligible for death, while individualized sentencing and mandatory appellate review protect against arbitrary or capricious imposition of the death penalty. The Constitution does not require the jury to apply specific standards for weighing aggravating and mitigating circumstances in selecting the sentence.
- Effect of an invalid aggravating circumstance on a death sentence supported by other aggravating circumstances. The death sentence did not have to be vacated merely because one of the aggravating circumstances found by the jury was later held invalid. The jury expressly found two valid and legally sufficient aggravating circumstances, so the verdict was not an unexplained general verdict that might have rested exclusively on the invalid ground.
- Constitutional significance of the erroneous sentencing instruction. The erroneous instruction concerning the vague aggravating circumstance did not require vacating the death sentence. The underlying prior-conviction evidence was properly admitted, respondent could explain or challenge it, the instruction did not make constitutionally impermissible conduct aggravating, and the circumstance's designation as statutory had an inconsequential impact under the Georgia Supreme Court's interpretation of the scheme.
Docket 81-89
Cited authorities
- Ohio Rev. Code Ann. § 2901.04
- Tenn. Code Ann. § 39-2-203
- 129 U. Pa. L. Rev. 1
- 42 Pa. Cons. Stat. § 9711
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- State of New Jersey, Plaintiff-Respondent v. Marko Bey (Ii), Defendant-Appellant
- Ronald Keith Williamson, Appellant v. State of Oklahoma, Appellee