Ramdass v. Angelone

Summary

The Court affirmed the Virginia Supreme Court's denial of habeas relief, holding that Simmons v. South Carolina did not require a parole-ineligibility instruction because petitioner was not legally ineligible for parole under state law at the time of sentencing, as final judgment had not yet been entered on a prior robbery conviction. Justice O'Connor concurred in the judgment, emphasizing the narrower standard of review on habeas, while Justice Stevens dissented, arguing the State's reliance on the conviction to prove future dangerousness entitled petitioner to rebut it with parole ineligibility information.