People v. LaValle
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| People v. LaValle | ||||||||
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| June 24, 2004 | ||||||||
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| The current statute of capital punishment in the state of New York was declared unconstitutional as it violated article one, section six of the state constitution. | ||||||||
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| New York State Constitution article one, section six |
People v. LaValle was a landmark decision by the New York Court of Appeals, the highest court in New York State, in which the court ruled that the state's death penalty statute was unconstitutional. The case was decided on June 24th, 2004.
[edit] Facts
Steven LaValle, who murdered high-school track coach Cynthia Quinn during her morning jog (the court states she was stabbed seventy-three times with a screwdriver) and then raped her, was convicted by a lower court of murder in the first degree and of rape. The Supreme Court of Suffolk County sentenced him to death. LaValle largely argued the case himself (despite a complete lack of legal training), after a fallout between himself and his two attorneys. Each wanted to take the case in a separate direction. The case was eventually appealed to the highest court in New York State.
LaValle argued that his death sentence had been improperly imposed on two grounds. First, he alleged that one of the jurors (juror 16) had been biased against him from the beginning, and that during voir dire the juror had expressed an inclination towards assigning the death penalty to rapists and murderers. LaValle also argued that the emotional testimony of Quinn's husband was largely irrelevant to the case, and served only to earn him a harsher sentence from the jury.
While the court upheld LaValle's conviction, citing "overwhelming evidence of guilt" to support it (largely based on LaValle's own confession as well as eyewitness testimony), the court did invalidate the death sentence, on the grounds that it violated article one, section six of the New York Constitution. The court ruled that, while other states may allow deliberately more severe sentences for criminals on the basis of their "future dangerousness" should they ever be released from prison, this line of legal thinking had no place under the New York State Constitution. Ultimately, the death sentence as well as the state's death penalty statute were invalidated, as the court decided that that a jury could potentially impose the death penalty on an unworthy convict out of fear that he/she may someday be released from prison.
[edit] Effects
The court remanded the case to the Supreme Court of Suffolk County with instructions that a new sentence be imposed: either 20 or 25 years to life, or life imprisonment without eligibility for parole. The death sentences of New York's other two death-row inmates were also invalidated.
As of July, 2006, there are no plans to write a new death penalty statute in the state of New York.
