Jones v. United States

Summary

The Court affirmed Jones's federal death sentence. Justice Thomas's majority opinion held that jury deadlock transfers sentencing responsibility to the judge under the Federal Death Penalty Act, but the Eighth Amendment does not require an instruction explaining that consequence, and the Court declined to require one through its supervisory authority. The majority also held that Jones's unpreserved challenge to the instructions and verdict forms was subject to plain-error review, that the charge as a whole did not create a reasonable likelihood of the alleged misunderstanding, and that Jones had not shown an effect on substantial rights. A four-Justice portion of Thomas's opinion, joined by Chief Justice Rehnquist and Justices O'Connor and Kennedy, concluded that the challenged nonstatutory aggravating factors were constitutionally valid. The five-Justice majority, including Justice Scalia, independently held that any error in those factors was harmless beyond a reasonable doubt. Justice Ginsburg dissented, joined by Justices Stevens and Souter and, as to Parts I, II, III, and V, Justice Breyer. The dissent argued that misleading instructions concerning a nonexistent lesser-sentence option undermined the reliability of the death verdict and warranted a new sentencing hearing; Ginsburg, Stevens, and Souter additionally criticized the overlapping aggravating factors. Breyer did not regard the unobjected-to instructions as plain error, but considered refusal of the requested corrective instruction an abuse of discretion.