Eddings v. Oklahoma (1981)
- Docket
- 80-5727
- Decided
- 1981-01-01
Summary
Question: Did the trial court commit a plain error when it failed to consider evidence of Eddings’ unhappy childhood and emotional disturbance in its consideration of mitigating and aggravating circumstances? Conclusion: Yes. In a 5-4 opinion written by Justice Louis Powell, the Court held that the trial court erred when it failed to consider mitigating evidence of Eddings’ unhappy childhood and emotional disturbance. Justice Powell looked to the Court’s decision in Lockett v. Ohio , where it held that a sentencer must consider any relevant aspect of a defendant’s character or record as mitigating factors toward imposing a sentence less than death. Justice Powell then determined that the trial judge refused to consider the mitigating evidence of Eddings’ family history as a matter of law, rather than finding that evidence wanting as a matter of fact. He also determined that the court of appeals limited the evidence of mitigating circumstances to the fact of Eddings’ youth. He emphasized that the undisputed evidence of Eddings’ violent background demonstrated that he was not a normal sixteen-year-old. Justice Powell held that the Oklahoma state courts must consider such evidence when imposing the death penalty, reversing the sentence and remanding the case for further proceedings. Justice William Brennan concurred, repeating his view that the death penalty is in all circumstances cruel and unusual punishment prohibited by the Eighth and Fourteenth Amendments. Justice Sandra Day O’Connor concurred, agreeing that the trial court incorrectly determined that it could not consider evidence of Eddings’ violent background as a matter of law. She emphasized that the majority’s holding did not change the Court’s opinions establishing the constitutionality of the death penalty; nor did it determine whether the Constitution permits the imposition of the death penalty on a sixteen-year-old. Chief Justice Warren Burger dissented, joined by Justices Byron White, Harry Blackmun, and William Rehnquist. He pointed out that the Court granted certiorari to answer whether it was constitutional to impose the death penalty on a sixteen-year-old offender, and that Eddings raised the evidentiary question for the first time in his brief to the Court. He argued that both the trial judge and the court of appeals actually weighed the evidence of Eddings’ violent background and found it lacking.