Supreme Court of Delaware
Benjamin Rauf, Defendant-Appellant v. State of Delaware, Plaintiff-Appellee — Vaughn, J., Dissenting
August 2, 20162016 Del. LEXIS 419
Summary
Justice Vaughn, dissenting, would have concluded that the Delaware death-penalty statute complies with the Sixth Amendment so long as a jury unanimously finds beyond a reasonable doubt at least one statutory aggravating circumstance necessary to make the defendant death-eligible. He read the governing United States Supreme Court decision as applying, rather than expanding, the existing rule requiring jury determination of facts that increase the maximum punishment, without requiring jury findings on every fact involved in weighing aggravating and mitigating circumstances or requiring jury sentencing. Chief Justice Strine and Justice Holland, concurring in the majority, interpreted the constitutional rule more broadly and concluded that Delaware's statute was invalid because the jury did not make all factual findings necessary for the ultimate death sentence.