Stebbing v. Maryland

Background

A 19-year-old woman, Annette Louise Stebbing, was sentenced to death in Maryland. She challenged the State’s capital-sentencing law and the way the trial court treated evidence about her youth, mental capacity, and drug use. The petition asked the high court to review whether Maryland’s rules for deciding life or death are constitutional.

Reasoning

The Court declined to hear the case and left the death sentence and Maryland’s sentencing procedures undisturbed. Two Justices dissented. Justice Marshall explained that the Maryland law requires juries or judges to find specific mitigating factors by a clear standard before they can consider them, prevents the sentencer from independently deciding whether death is appropriate, and can be read to put the practical burden on the defendant to prove why he or she should not be executed. Justice Marshall relied on prior cases that require sentencers to consider all relevant mitigating evidence. Justice Brennan wrote separately that he believes the death penalty is always unconstitutional and would have vacated the sentence.

Real world impact

Because the Court refused review, the Maryland sentence and the statute’s procedures remain in force for this defendant and similar cases for now. The denial is not a ruling on the law’s constitutionality and denials carry no precedential weight, so the constitutional questions raised by the dissents could be argued again in later cases or on further appeal.

Dissents or concurrances

The dissents stressed two views: Marshall detailed specific procedural and burden-of-proof problems with Maryland’s statute; Brennan reiterated his view that the death penalty is always cruel and unusual.