Wiley v. Mississippi

Background

A man named William Wiley was convicted in Mississippi of a murder that occurred during a robbery and was sentenced to death. The state high court initially sent the case back for a new sentencing because of improper prosecutor remarks, but after a second sentencing the jury again imposed death and the state court affirmed that sentence.

Reasoning

The Supreme Court denied Wiley’s request for review, so the state court decision stands. Justice Marshall, joined by Justice Brennan, wrote a dissent arguing the Court should have taken the case. He said the sentencing was biased because two of the aggravating factors the jury found simply repeated the same fact that made the crime a capital offense — that the murder happened during a robbery — which unfairly pushed the jury toward death. He also questioned whether the “especially heinous” factor was too vague under earlier decisions.

Real world impact

Because the Court declined review, Wiley’s death sentence remains in effect and Mississippi’s way of using those aggravating factors remains unreviewed by the nation’s highest court. The denial does not resolve the constitutional questions Marshall raised, so similar challenges in other cases or courts could still change the law later. The dissent said the unresolved conflict among lower courts makes further review important.

Dissents or concurrances

Justice Marshall would have granted review to address the double-counting of sentencing factors and the potential vagueness of the “heinous” factor, warning that the scheme risks arbitrary death sentences and noting a circuit split on the issue.