Dawson v. Delaware

Summary

The Court held that the First and Fourteenth Amendments prohibited admitting evidence of Dawson's Aryan Brotherhood membership at his capital sentencing because the evidence established only abstract beliefs unrelated to the crime, aggravating circumstances, or mitigating evidence. It rejected a categorical prohibition on sentencing evidence concerning constitutionally protected beliefs and associations. The Court vacated the Delaware Supreme Court's judgment and remanded, leaving harmless error open for consideration. Justice Blackmun, concurring without any other Justice joining, emphasized that the Court did not require harmless-error review and suggested that such review might be inappropriate. Justice Thomas dissented alone, reasoning that prison-gang membership was relevant character and future-dangerousness evidence, rebutted Dawson's mitigation, and did not warrant relief under either the First Amendment or due process.