Oregon v. Guzek
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| Oregon v. Guzek | |||||||||||||||
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| Argued December 7, 2005 Decided February 22, 2006 |
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| Holding | |||||||||||||||
| States may constitutionally limit the evidence of innocence a defendant convicted of a capital offense may present at his sentencing hearing to the evidence already presented at his trial. Oregon Supreme Court vacated and remanded. | |||||||||||||||
| Court membership | |||||||||||||||
| Chief Justice: John Roberts Associate Justices: John Paul Stevens, Antonin Scalia, Anthony Kennedy, David Souter, Clarence Thomas, Ruth Bader Ginsburg, Stephen Breyer, Samuel Alito |
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| Case opinions | |||||||||||||||
| Majority by: Breyer Joined by: Roberts, Stevens, Kennedy, Souter, Ginsburg Concurrence by: Scalia Joined by: Thomas Alito took no part in the consideration or decision of the case. |
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| Laws applied | |||||||||||||||
| U.S. Const. amend. VIII | |||||||||||||||
Oregon v. Guzek, 546 U.S. 517 (2006), was a decision by the Supreme Court of the United States, which ruled that the Eighth Amendment to the United States Constitution does not grant criminal defendants facing the death penalty the right to introduce new evidence of their innocence during sentencing that was not introduced during trial. Accordingly, states could constitutionally exclude such evidence from the sentencing phase of a capital trial.
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[edit] Background of the case
[edit] First state appeal
Randy Lee Guzek was convicted of murder and sentenced to death.[1] On appeal, the Oregon Supreme Court affirmed his conviction but vacated the sentence.[2] The court ruled that the death sentence violated the Eighth Amendment[3] because the jury was not presented with a "general mitigation question," which would ensure that it had the opportunity to give effect to any relevant mitigating evidence outside of the statutory factors that were submitted to it. The court remanded the case back to the trial court for a new sentencing trial.
[edit] Second state appeal
On remand, Guzek was sentenced to death again.[4] He appealed, and the Oregon Supreme Court again vacated the sentence, ruling that "victim impact" evidence that the State had presented during sentencing was not relevant, and so unconstitutionally secured the death sentence.[5] The case was remanded for a third sentencing trial.
[edit] Third state appeal
During the third sentencing trial, the trial judge failed to instruct the jury about a "true-life" sentencing option—life in prison without the possibility of parole—as an alternative to the death penalty.[6] Guzek was once again sentenced to death. Based on this error, the Oregon Supreme Court once again vacated Guzek's sentence and remanded for a new sentencing trial.[7]
Seeking to avoid further errors at his fourth sentencing proceeding, the court also addressed the exclusion of alibi evidence that Guzek had sought to admit, which consisted of transcripts of testimony by his mother and grandfather stating he was with them at the time of the murder. The Oregon Supreme Court ruled that under state law and the Eighth Amendment, Guzek had a right to present this evidence during his death penalty sentencing, and directed the trial court to admit all alibi evidence he submitted. The State of Oregon then petitioned the Supreme Court for review.
[edit] The Court's decision
The United States Supreme Court unanimously reversed the Oregon Supreme Court, ruling that the Eighth Amendment's prohibition against cruel and unusual punishment did not create a right to introduce evidence of innocence in a defendant's death penalty sentencing phase if it had not been introduced in the trial phase. States instead were permitted by the U.S. Constitution to limit such evidence to that which was already presented at trial.
Guzek had also argued that this alibi evidence could be used to impeach the testimony of other witnesses, and the Court left it open to the Oregon Supreme Court on remand to determine whether this was permissible under Oregon law.
The victims of Randy Guzek were named Rod and Lois Houser. The story of the case is told in an award-winning series of columns by the Portland OREGONIAN's Steve Duin [[1]]
[edit] See also
[edit] Notes
- ^ Deschutes County Circuit Court, Judge Thomas M. Mosgrove presiding.
- ^ State v. Guzek, 797 P.2d 1031 (Ore. 1990).
- ^ As applied to the States by the Fourteenth Amendment to the United States Constitution; see Incorporation.
- ^ Judge Musgrove again presided over the sentencing.
- ^ State v. Guzek, 906 P.2d 272 (Ore. 1995).
- ^ Judge Pierre Van Rysselberghe presided over the third sentencing.
- ^ State v. Guzek, 86 P.3d 1106 (Ore. 2004).
