Ramdass v. Angelone

Summary

Justice Stevens dissents, arguing the plurality wrongly distinguishes Simmons v. South Carolina based on the timing of judgment entry rather than the verdict itself. He contends that due process requires informing juries of parole ineligibility when future dangerousness is argued, regardless of technical state-law formalities. Justice O'Connor, concurring in the judgment, agrees the Virginia Supreme Court decision was not contrary to Simmons under the AEDPA standard.