Supreme Court of the United States
Tuilaepa v. California
June 30, 1994512 U.S. 967
Summary
The Court, in an opinion by Justice Kennedy joined by Chief Justice Rehnquist and Justices O'Connor, Scalia, Souter, and Thomas, upheld California's capital-sentencing factors concerning the circumstances of the crime, prior violent criminal activity, and the defendant's age against Eighth Amendment vagueness challenges. Selection factors may direct jurors to relevant subjects without posing specific factual questions, and jurors need not receive instructions assigning particular weights to the evidence. The Court affirmed both California Supreme Court judgments without deciding the adequacy of California's death-eligibility provisions. Justice Scalia concurred separately, maintaining that the Eighth Amendment's distinctive procedural requirements end once eligibility has been adequately narrowed. Justice Souter concurred, emphasizing the factors' common-sense clarity. Justice Stevens, joined by Justice Ginsburg, concurred in the judgment because relevant sentencing evidence need not be labeled aggravating or mitigating. Justice Blackmun dissented, maintaining both that capital punishment cannot be administered constitutionally and that the challenged factors insufficiently constrain discretion and permit arbitrary or racially influenced sentencing.
Holding
- Vagueness of the circumstances-of-the-crime factor.. Section 190.3(a)'s direction to consider the circumstances of the crime and special circumstances found true does not violate the Eighth Amendment.
- Vagueness of the prior violent criminal activity factor.. Section 190.3(b)'s direction to consider criminal activity involving force, violence, or threats is not unconstitutionally vague.
- Vagueness of the defendant's age factor.. Section 190.3(i)'s direction to consider the defendant's age at the time of the crime is constitutionally permissible.
- Whether selection factors must require answers to specific factual questions.. The Constitution permits capital-sentencing selection instructions that identify relevant subjects without requiring answers to specific propositional questions.
- Whether jurors must be instructed how to weigh particular sentencing facts.. A capital sentencer need not receive instructions specifying how to weigh any particular fact in choosing the sentence.
Docket 93-5131
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