Maynard v. Cartwright

Background

A man convicted of murdering a husband and brutally attacking his wife in Oklahoma was sentenced to death after a jury found two statutory aggravating factors. State courts affirmed the conviction and sentence. The federal appeals court reviewed one aggravating factor — that the murder was “especially heinous, atrocious, or cruel” — and held that the phrase was too vague, vacated the death sentence, and barred execution while allowing the state to retry the sentencing question. The State asked the Supreme Court to decide whether that aggravating phrase was constitutional.

Reasoning

The core question was whether the words used in the statute gave juries meaningful guidance so death sentences would not be arbitrary. The Court relied on earlier decisions saying capital statutes must channel jury discretion. It concluded that the Oklahoma language, as applied by Oklahoma courts then, did not sufficiently limit jury discretion. The Court rejected the State’s argument that shocking facts alone save the statute. The Supreme Court affirmed the appeals court’s judgment and left the door open for the state to conduct new sentencing proceedings under constitutionally acceptable rules.

Real world impact

The ruling means this use of “especially heinous, atrocious, or cruel” cannot support a death sentence unless the state supplies a narrowing rule that gives juries clear standards. The immediate effect was to vacate the sentence at issue and permit the state to revisit sentencing. States with similar wording must ensure clearer limits before seeking the death penalty.

Dissents or concurrances

Justice Brennan, joined by Justice Marshall, concurred only to say he would bar any reimposition of the death penalty because he views it as always unconstitutional.