Adams v. South Carolina

Background

A man convicted of murder in South Carolina was sentenced to death. At his trial the judge told jurors that a “reasonable doubt” meant a substantial, strong, well-founded doubt or “a doubt for which you give a reason.” The defendant objected to that instruction, appealed, and the South Carolina Supreme Court affirmed his conviction and death sentence without allowing briefing or argument on that instruction. The defendant then asked the U.S. Supreme Court to review the case.

Reasoning

The U.S. Supreme Court declined to take the case and denied review, leaving the state court’s decision in place. The core question raised was whether the trial court’s definition of reasonable doubt improperly reduced the prosecutor’s burden to prove guilt. Justice Marshall, joined by Justice Brennan, dissented from the denial, arguing that the instruction equated reasonable doubt with a substantial or articulable doubt and therefore eased the government’s proof obligation. He noted that federal and state courts are divided on this issue and cited a federal appellate ruling that struck down a very similar instruction.

Real world impact

Because the Court denied review, the death sentence and the underlying conviction remain intact for now. The decision does not settle the constitutional question about how to define reasonable doubt nationwide. The disagreement among state and federal courts over such jury instructions remains unresolved and could lead to future review.

Dissents or concurrances

Justice Marshall would have granted review and, even setting aside his view that the death penalty is always unconstitutional, would have vacated the sentence because he viewed the instruction as unconstitutional and in conflict with other courts’ rulings.