Eddmonds v. Illinois

1984-12-03

Headline: Justices decline to review Illinois death-penalty law that lets county prosecutors alone decide who faces a death sentencing proceeding, leaving concerns about unguided, potentially arbitrary prosecutorial discretion unresolved.

Holding: The Court denied review of the challenge, leaving the Illinois statute that lets prosecutors decide whether to seek death sentencing in place and not ruling on its constitutionality.

Real World Impact:

Leaves county prosecutors free to decide who faces death sentencing.
Increases risk of unequal or arbitrary application of the death penalty.
Keeps no guaranteed statewide comparative review of death sentences.

Topics: death penalty, prosecutorial discretion, arbitrary sentencing, criminal appeals

Summary

Background

A defendant in Illinois asked the Supreme Court to review the State’s death penalty law. The law triggers a death sentencing proceeding only "where requested by the State," meaning a prosecutor’s request is necessary for a defendant to face death. The statute contains no legislative standards guiding that prosecutorial decision.

Reasoning

The central question raised is whether giving prosecutors unlimited choice to start death sentencing proceedings is constitutional. Justice Marshall, joined by Justice Brennan, argued the Court should take the case because the discretion at this post-conviction stage is unguided and therefore risks arbitrary, capricious, or discriminatory results. He relied on earlier decisions saying post-conviction death decisions must be limited by standards, and he warned that placing this power in 102 county prosecutors creates inconsistent policies across the State. He also noted Illinois does not require clear comparative proportionality review on appeal, which would otherwise help assure similar cases are treated alike.

Real world impact

Because the Court denied review, the Illinois statute remains in effect and the Supreme Court did not rule on its constitutionality. The practical result leaves in place a system where county prosecutors decide who is considered for the death penalty, with an increased risk of unequal treatment and no guaranteed statewide review to compare sentences. The denial is not a final judgment on the law’s constitutionality and the issue could be raised again.

Dissents or concurrances

Justice Marshall dissented from the denial and would have granted review, arguing the statute’s unguided prosecutorial discretion merits Supreme Court scrutiny; Justice Brennan joined that dissent.