Williams v. Lynaugh, Director, Texas Department of Corrections

Background

James Williams was sentenced to death under a Texas law that required the jury to find beyond a reasonable doubt that he would commit violent acts in the future. At sentencing the State relied largely on eyewitness testimony that Williams had joined a restaurant robbery ten days before the murder, although he was never charged or convicted for that robbery. The trial court did not instruct the jury to find the robbery occurred before using the testimony, and the Court of Appeals rejected Williams’ constitutional claims. The Supreme Court denied review.

Reasoning

The core question is whether a State may use allegations of unproven crimes at the punishment phase of a capital trial. Justice Marshall, dissenting from the denial of review, argued that such evidence lacks the reliability of a conviction and that relying on mere allegations undermines the special need for reliability in death-penalty cases. He warned that requiring a jury finding beyond a reasonable doubt on those allegations would be impractical and biased because the same jury already found the defendant guilty. State courts are divided, and Texas permits the evidence in capital cases while generally forbidding it in noncapital cases.

Real world impact

Because the Court refused to hear the case, the lower-court ruling stands and Texas’ practice of admitting unadjudicated-offense evidence in capital sentencing remains in place for now. Capital defendants in Texas and jurisdictions that follow similar rules may face sentencing that considers allegations not proven at trial. The Supreme Court did not resolve the national question, so the issue remains unsettled and could return for review later.

Dissents or concurrances

Justice Marshall (joined by Justice Brennan) would have granted review to decide whether admitting uncharged or unproven crimes at capital sentencing is consistent with protections against cruel punishment and whether allowing that evidence only in capital cases violates equal protection; he also reiterated his view that the death penalty is unconstitutional.