California v. Ramos

Background

California prosecuted Marcelino Ramos, a fast-food restaurant janitor, for robbery and murder after he shot two employees, killing one. At the separate penalty phase the jury heard mitigation evidence. California law allowed death or life without parole when a special circumstance was found, and a statute required the judge to tell jurors that the Governor can commute a life-without-parole sentence to one that allows parole. The trial judge gave that "Briggs Instruction," the jury returned a death verdict, and the California Supreme Court reversed the death sentence, finding the instruction speculative and misleading.

Reasoning

The Court considered whether telling jurors about possible commutation violates the Eighth or Fourteenth Amendments. The majority concluded the instruction is constitutional. It relied on prior decisions that permit juries to consider a defendant’s probable future dangerousness, said the instruction prompts an individualized judgment about the defendant, and described the instruction as accurate information correcting a misleading label for one sentencing option. The Court rejected arguments that the instruction injects too much speculation or improperly diverts the jury, and it noted state law reasons why an instruction about commuting death sentences was not given.

Real world impact

The ruling lets trial judges in California and other States that choose to do so inform capital juries about a Governor’s power to commute life-without-parole sentences. The decision reverses the California Supreme Court and sends the case back for further proceedings. States remain free to prohibit such instructions under state law, and the majority emphasized that legislatures or state courts can provide greater protections.

Dissents or concurrances

Several Justices dissented, arguing the instruction is misleading, invites guesswork about future release, and places an irrelevant factor before juries; others criticized the Court’s decision to hear the case.