South Carolina v. Gathers
South Carolina v. Gathers | |||||||
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Argued March 28, 1989 Decided June 12, 1989 | |||||||
Full case name | Demitrius Gathers v. Tennessee | ||||||
Citations |
490 U.S. 805 | ||||||
Prior history | Certiorari to the Supreme Court of South Carolina | ||||||
Holding | |||||||
Victim impact evidence is only relevant at the sentencing stage and thus admissible, if it directly relates to the circumstances of the crime. The content of religious cards possessed by the victim cannot equate to such relevance, and contribute nothing to the defendant's blameworthiness. | |||||||
Court membership | |||||||
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Case opinions | |||||||
Majority | Brennan, joined by White, Marshall, Blackmun, Stevens | ||||||
Concurrence | White | ||||||
Dissent | O'Connor, joined by Rehnquist, Kennedy | ||||||
Dissent | Scalia | ||||||
Overruled by | |||||||
Payne v. Tennessee |
South Carolina v. Gathers, 490 U.S. 805 (1989) was a United States Supreme Court which held that testimony in the form of a victim impact statement is only admissible during the sentencing phase of a trial if it directly relates to the 'circumstances of the crime'. This case was later overruled by the Supreme Court decision in Payne v. Tennessee 501 U.S. 808 (1991).[1]
Reasoning
The Court held that their opinion in Booth v. Maryland left open the possibility that the kind of information contained in victim impact statements could be admissible if it "relate[d] directly to the circumstances of the crime." Though South Carolina asserted that such is the case here, the Brennan-led majority disagreed, holding the content of the cards at issue to be irrelevant to the "circumstances of the crime."
Four Justices dissented: Sandra Day O'Connor, William Rehnquist, Anthony Kennedy and Antonin Scalia.
Impact
The impact of the case was somewhat short-lived, as two years later the Rehnquist Court decided Payne, which has since had a significant, ongoing impact in victim's rights,[2] criminology, the law, the Court itself, and the lives of the parties involved; far wider-reaching than the impact of Gathers.[3]
See also
- Crime in the United States
- Criminology
- Crime victim advocacy program
- List of United States Supreme Court cases, volume 490
- 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
- Victimology
- Victim Support
- Victim study
References
- ↑ Judgment is re-worded from the decision, q.v., Supreme.Justia.com. Retrieved October 31, 2012.
- ↑ Donahoe, Joel F. (1999). "The Changing Role of Victim Impact Evidence in Capital Cases". Western Criminology Review 2 (1). Retrieved 2012-10-31.
- ↑ Slowinski, Richard Lee (1990). "Note: South Carolina v. Gathers: Prohibiting the Use of Victim-Related Information in Capital Punishment Proceedings". Catholic University Law Review Fall (40): 215.