Adams v. Wainwright, Secretary, Florida Department of Corrections, Et Al.

Background

A man, Aubrey Adams, was convicted of killing an eight‑year‑old girl in Florida and was sentenced to death. He told police he removed the child’s clothes, tied her hands, and put plastic bags over her body, and said he thought he had tried to have sexual relations. The indictment accused him of premeditated strangling, but the jury was told it could convict either for premeditated murder or for killing during certain felonies, including rape or a “crime against nature.” The Florida Supreme Court had earlier treated the term “crime against nature” as too vague to support a conviction.

Reasoning

The Supreme Court declined to hear the appeal and left the conviction and death sentence in place. The key dispute raised by dissenting Justices was that the jury’s general guilty verdict might have rested on a felony‑murder theory tied to sexual conduct that state law later deemed invalid or too vague. One dissenting Justice relied on the principle that when a jury may base a general verdict on two independent grounds and one ground is invalid, the verdict cannot stand because it is impossible to know which ground the jury used. Another dissenting Justice argued more broadly that the death penalty is always cruel and would have vacated the sentence.

Real world impact

Because the Court refused to review the case, Florida may proceed toward execution while the instructional and vagueness questions remain unresolved. The ruling leaves the conviction intact unless another court later intervenes. The case shows how vague criminal terms and broad jury instructions can have life‑or‑death consequences.

Dissents or concurrances

Two Justices dissented: one on absolute opposition to the death penalty and another stressing that a general verdict possibly based on an invalid theory requires setting aside the conviction.