Waye v. Morris, Superintendent, Mecklenburg Correctional Center
Headline: Court refuses review in a death-penalty case, leaving a man’s murder conviction and death sentence intact despite dissents urging review over flawed jury instructions and lawyer errors.
Holding: The Court denied the defendant’s request for review and left his murder conviction and death sentence in place, declining to address claims about a faulty jury instruction and counsel’s performance.
- Leaves the man's conviction and death sentence in place.
- Keeps unresolved questions about defective jury instructions and harmlessness.
- Calls attention to potential ineffective-lawyer claims in capital trials.
Summary
Background
A man was convicted of capital murder in April 1978 and sentenced to death. His only defense was that the killing lacked premeditation; the record shows he had been drinking, called police saying he "had killed somebody," and led officers to the body. The trial judge gave a jury instruction saying a person is "presumed to intend that which he does," language later found constitutionally flawed in a separate case decided after this trial.
Reasoning
The Supreme Court declined to take the case, so it left the lower-court outcome in place without resolving the central dispute. The main legal question is whether the defendant’s trial lawyer was ineffective for failing to object to the burdenshifting jury instruction, especially given earlier decisions that should have put lawyers on notice. Justice Marshall argued the lawyer’s failure fell below acceptable standards and that the state courts handled the claim poorly. He urged the Court to grant review, apply the Court’s standard for ineffective counsel, and reconsider the death sentence. Justice Brennan separately argued the death penalty is always unconstitutional and would have vacated the sentence.
Real world impact
Because the Court denied review, the conviction and death sentence remain in force for now. The decision leaves unresolved how courts should treat similar jury instructions and whether such errors can be harmless. State and federal courts may still revisit the claim on habeas or in later appeals, and the practical question of whether defendants can get new trials based on similar lawyer errors remains open.
Dissents or concurrances
Two Justices dissented: one on broad opposition to the death penalty, the other focused on the lawyer’s failure to object to a constitutionally defective instruction and on remanding the case for correct application of the ineffective-counsel standard.
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