Mills v. Maryland

Background

Ralph Mills was convicted of murdering his cellmate and a Maryland jury found one aggravating factor: the killing occurred while he was confined. The defense introduced mitigating evidence — his youth, mental problems, low future dangerousness, and poor rehabilitation — but the jury marked “no” beside each listed mitigating circumstance on a yes/no sentencing form and returned a death sentence.

Reasoning

The Court asked whether a reasonable juror could have understood the judge’s instructions and the verdict form to mean that all 12 jurors had to agree about each mitigating factor before anyone could consider it. The Court concluded there was a substantial probability jurors were so informed. Because the sentencer must be allowed to consider any mitigating evidence an individual juror finds, the Court held the death sentence could not stand and ordered vacatur and resentencing.

Real world impact

The ruling requires that juries and sentencing forms not prevent a single juror from considering mitigating evidence. Maryland revised its form to let jurors report nonunanimous findings and to instruct that each juror may weigh mitigating evidence they individually find. The decision is not a final merits ruling on guilt; it simply requires a new sentencing hearing consistent with this opinion.

Dissents or concurrances

Two Justices concurred with the result (one urging broader limits on reimposing death). The Chief Justice dissented, arguing a reasonable juror would have understood the instructions and would have affirmed the sentence.