Lowenfield v. Phelps
Lowenfield v. Phelps, 484 U.S. 231 (1988), is a United States Supreme Court case in which the Court held that the two jury polls and the supplemental charge did not impermissibly coerce the jury to return a death sentence, and that the death sentence does not violate the Eighth Amendment simply because the single statutory "aggravating circumstance" found by the jury duplicates an element of the underlying offense of first-degree murder.
| Lowenfield v. Phelps | |
|---|---|
 | |
| Argued October 14, 1987 Decided January 13, 1988 | |
| Full case name | Lowenfield v. Phelps, Secretary, Louisiana Department of Corrections, et al. |
| Citations | 484 U.S. 231 (more) 108 S. Ct. 546; 98 L. Ed. 2d 568; 1988 U.S. LEXIS 313; 56 U.S.L.W. 4071 |
| Case history | |
| Prior | Habeas corpus petition denied, 671 F. Supp. 423 (E.D. La. 1987); affirmed, 817 F.2d 285 (5th Cir. 1987); stay of execution granted, 482 U.S. 932 (1987); cert. granted, 483 U.S. 1005 (1987). |
| Subsequent | Rehearing denied, 485 U.S. 944 (1988). |
| Holding | |
| The aggravating factor making the crime punishable by death may be found in the definition of the crime itself as long it is enough narrow and precise. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Rehnquist, joined by White, Blackmun, O'Connor, Scalia; Stevens (part III, except the last sentence) |
| Dissent | Marshall, joined by Brennan; Stevens (part I) |
| Kennedy took no part in the consideration or decision of the case. | |
| Laws applied | |
| U.S. Const. amend. VIII | |
Background
In 1984, Leslie Lowenfield, a Guyanese immigrant welder, was convicted of the 1982 killing of his girlfriend, a sheriff's deputy, and four members of her family, including a 4-year-old girl.[1]
Opinion of the court
The court, in an opinion by Chief Justice Rehnquist, held that the trial judges's polling of the jury and supplemental Allen instruction did not coerce the jury to return a verdict of guilty. The Court also rejected a challenge that Louisiana's death penalty statute did not sufficiently narrow the category of defendants who are eligible for the death penalty. The aggravating circumstance in the case, intentionally killing more than one person was found by the jury in the guilt phase after returning 3 first degree murder verdicts.
Subsequent developments
Lowenfield was executed by electric chair on April 13, 1988.[2]
See also
- List of United States Supreme Court cases, volume 484
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court
General:
References
- "Louisiana Executes Man, 34, Convicted of Murdering Five". The New York Times. 13 April 1988.
- "Convicted Murderer Dies In Louisiana Electric Chair". Associated Press. 13 April 1988.
External links
- Text of Lowenfield v. Phelps, 484 U.S. 231 (1988) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)