Supreme Court of the United States
Parker v. Dugger
January 22, 1991498 U.S. 308
Summary
The Court held that the Florida Supreme Court’s conclusion that the trial judge found no non‑statutory mitigating circumstances was not fairly supported by the record, rendering Parker’s death sentence unconstitutional; it reversed the Eleventh Circuit and remanded for further state proceedings. Justice White dissented, arguing the majority’s factual reconstruction was unwarranted.
Holding
- Whether the Florida Supreme Court’s finding that the trial judge found no mitigating circumstances was fairly supported by the record.. The Court held that the finding was not fairly supported; the trial judge had in fact considered and found non‑statutory mitigating circumstances, so the Florida Supreme Court erred.
- Whether Parker’s death sentence violated the Eighth Amendment’s prohibition on arbitrary and irrational imposition of capital punishment.. The death sentence was unconstitutional because the state’s review was arbitrary and failed to give Parker individualized consideration of mitigating evidence.
- Whether the determination of what the trial judge found is a factual issue subject to deference under 28 U.S.C. §2254(d)(8).. The Court held that it is a factual issue; federal courts must not overturn a state factual finding unless it is not fairly supported by the record.
- Whether Florida’s statutory “clear and convincing” standard for overriding a jury’s life‑sentence recommendation is constitutionally permissible.. The Court upheld the statutory standard as permissible, but required that the judge actually consider all mitigating evidence before invoking it.
Docket 89-5961
Cited authorities
- Fla. Stat. § 921.141(6)
- Fla. Stat. §§921.141
- Fla. Stat. §921.141
- Fla. Stat. §921.141
- Fla. Stat. §921.141
- 28 U.S.C. § 2254