Hicks v. Oklahoma

1980-06-16

Headline: Court vacates a 40-year mandatory sentence and rules that denying a jury its state-law sentencing role violated due process, affecting defendants sentenced under Oklahoma’s invalid habitual-offender law.

Holding: The Court held that Oklahoma violated the Fourteenth Amendment by enforcing a 40-year sentence imposed under an unconstitutional habitual-offender statute that denied the defendant the jury sentencing state law guaranteed.

Real World Impact:

Stops enforcement of mandatory sentences imposed under an invalid habitual-offender law.
Requires states to respect a jury’s sentencing role when state law grants it.
May lead to resentencing or new jury sentencing in affected cases.

Topics: jury sentencing, mandatory prison terms, due process, habitual-offender laws

Summary

Background

The case involves a man tried in Oklahoma for unlawfully distributing heroin. Because he had two prior felony convictions, the jury was instructed under a state habitual-offender law to impose a mandatory 40-year sentence if it found him guilty. The jury convicted him and followed that instruction. After his trial, the same statutory provision was declared unconstitutional in another state case, and the Oklahoma appellate court nevertheless affirmed his 40-year sentence.

Reasoning

The Court asked whether the State deprived the defendant of due process by denying him the jury-determined sentence that Oklahoma law promised. The majority explained that when a State gives juries the power to fix punishment, a defendant has a legitimate expectation that the jury will exercise that discretion. Because the jury never had a valid opportunity to consider a lesser sentence once it was told to impose 40 years, the Court found the denial of that jury role an arbitrary deprivation of liberty under the Fourteenth Amendment and vacated the judgment.

Real world impact

The decision requires courts to respect a state-created right to jury sentencing when that right exists, and it undermines efforts to uphold sentences imposed under an invalid statutory scheme simply by saying the sentence could have been the same. The case was remanded to the Oklahoma Court of Criminal Appeals for further proceedings, so affected defendants may obtain new sentencing proceedings.

Dissents or concurrances

Justice Rehnquist dissented, arguing the defendant had in fact been sentenced by a jury and that the state court’s decision did not necessarily deny any federal right; he would have affirmed the state court.