Romano v. Oklahoma (SCOTUS 1994), 512 U.S. 1

Summary

The Supreme Court affirmed Romano's Oklahoma death sentence for the Sarfaty murder, holding that admission at sentencing of the judgment imposing a prior death sentence on him for the Thompson murder violated neither the Eighth nor the Fourteenth Amendment. Reading the Caldwell principle through Justice O'Connor's controlling narrower concurrence, the Court found the jury was not affirmatively misled about its role, and it declined to convert state-law irrelevance into federal constitutional error, asserting that the Eighth Amendment establishes no federal code of evidence for capital sentencing. Applying the Donnelly fundamental-fairness framework, it concluded the evidence did not so infect the sentencing proceeding as to deny due process, particularly since the invalidated aggravator was struck and the remaining three aggravators reweighed against mitigation yet still sustained death. Justice O'Connor filed a short concurrence stressing that the evidence was accurate when admitted; Justice Blackmun joined Justice Ginsburg's dissent, which argued the evidence risked diminishing jury responsibility and would have vacated the sentence and remanded for a new sentencing hearing.

Holding

Whether admitting evidence, at the sentencing phase, that the defendant had already been sentenced to death for another murder impermissibly undermined the jury's sense of responsibility under the Caldwell principle (Eighth and Fourteenth Amendments).. No. The admission of the judgment and sentence from the Thompson murder did not contravene Caldwell because the jury was not affirmatively misled regarding its role: the evidence was accurate when admitted, did not pertain to the jury's sentencing role, and the trial court's instructions emphasized the jury's responsibility and confined it to the four enumerated aggravators.

Whether the jury's consideration of evidence that was irrelevant under state law — and whose underlying conviction was later overturned — rendered the capital sentencing proceeding so unreliable as to violate the Eighth Amendment.. No. That evidence may be irrelevant as a matter of state law does not render its admission federal constitutional error; the Eighth Amendment does not establish a federal code of evidence to supersede state evidentiary rules in capital sentencing proceedings.

Whether admission of the evidence of the prior death sentence so infected the sentencing proceeding with unfairness as to make the jury's imposition of death a denial of due process under the Fourteenth Amendment.. No. Applying the Donnelly fundamental-fairness framework, the Court agreed with the Oklahoma Court of Criminal Appeals that the admission did not deprive petitioner of a fair sentencing proceeding.

Summary

Holding

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