Supreme Court of the United States
Sattazahn v. Pennsylvania
January 14, 2003537 U.S. 101
Summary
The Court held that Pennsylvania could seek the death penalty at Sattazahn's retrial because the first capital-sentencing jury had deadlocked without acquitting him of the greater offense and the mandatory life sentence therefore did not terminate jeopardy. It also rejected his due-process claim, reasoning that any state-law interest in the life sentence was not immutable and was lost through the process he invoked to overturn the underlying conviction. Justice O'Connor concurred in the judgment on narrower double-jeopardy grounds, while Justice Ginsburg, joined by three Justices, would have held that the final life judgment barred a second death-penalty proceeding.
Holding
- Double jeopardy and retrial for capital sentencing. The Double Jeopardy Clause did not bar Pennsylvania from seeking the death penalty at retrial. A hung sentencing jury that made no findings about aggravating circumstances did not acquit Sattazahn of the greater capital offense, and the judge's mandatory life sentence was not an acquittal because it rested on no factual findings.
- Due process and finality of the first life sentence. The Due Process Clause did not independently bar Pennsylvania from seeking the death penalty on retrial.
Docket 01-7574
Cited by
- Commonwealth v. John F. Petetabella
- Admilson Vizcaino v. Commonwealth
- United States v. Mickayla Peters
- United States, Appellee v. Garry Julien, Defendant, Appellant
- Aurelio Pinero, Jr., Petitioner, Appellant v. Paul H. Verdini, Respondent, Appellee
- Chestnut v. Milwaukee County Circuit Court
- Garcia v. Shinn
- (DP) Catlin v. Davis