Teague v. Tennessee

1985-07-01

Headline: Death-penalty review denied as Court declines to review Tennessee’s rule forcing defendants to prove mitigating factors outweigh aggravators, leaving jury instructions that make life sentences harder for some defendants.

Holding: The Court declined to take up the challenge and denied review, leaving in place Tennessee’s statutory scheme that requires defendants to prove mitigating circumstances outweigh aggravating ones, as the lower court applied.

Real World Impact:

Leaves Tennessee’s sentencing rule intact, making life sentences harder for some defendants.
Allows jury instructions that suggest only measurable mitigation can avoid the death penalty.

Topics: death penalty, jury instructions, mitigating circumstances, state sentencing law

Summary

Background

Raymond Eugene Teague, a man facing a death sentence in Tennessee, challenged the State's capital-sentencing rule. Tennessee law says that if the jury unanimously finds one or more statutory aggravating facts proved beyond a reasonable doubt, and those facts are not outweighed by mitigating circumstances, the sentence must be death. The jury in Teague’s case was given that instruction. The Supreme Court declined to take the case and denied review.

Reasoning

The central question raised in the dissent was whether Tennessee’s rule and the jury instructions limit the jury’s role in a way that conflicts with earlier Eighth Amendment rulings. Justice Marshall, joined by Justice Brennan, argued that the Eighth Amendment requires juries to be free to decide whether death is appropriate in the individual case. He cited previous decisions saying juries must be able to consider a defendant’s character, record, or mercy even when those factors do not numerically outweigh aggravators. Marshall concluded Tennessee’s statute likely misleads juries into thinking only easily labeled, countable mitigating facts count.

Real world impact

Because the Court denied review, the Tennessee sentencing rule and the related jury instruction remain in effect for now. That leaves juries in Tennessee following a procedure that emphasizes weighing formal mitigating factors against aggravating ones. This denial is not a final ruling on the rule’s constitutionality and could be revisited if the Court later takes a similar case.

Dissents or concurrances

Justice Marshall wrote a dissent from the denial of review, joined by Justice Brennan, saying he would have granted review to examine the statute’s consistency with Eighth Amendment precedents.