Blystone v. Pennsylvania

Background

A jury convicted Scott Wayne Blystone of robbing and murdering a hitchhiker, Dalton Charles Smithburger, Jr. The record shows Blystone picked up the hitchhiker, robbed him of $13, ordered him into a field, and shot him six times in the head. Blystone was recorded later bragging about the killing. At a separate sentencing hearing the jury found one statutory aggravating circumstance — that the killing occurred during a felony — and found no mitigating circumstances, after which the jury returned a death sentence under Pennsylvania law.

Reasoning

The central question was whether Pennsylvania’s statute is unconstitutional because it requires death when the jury finds at least one aggravating factor (things that make the crime more serious) and no mitigating factors (reasons to impose less than death). The Court held the statute and Blystone’s sentence constitutional. It stressed that the statute gives juries a nonexclusive list of mitigating matters and a catchall, so juries may consider any relevant mitigating evidence. Citing prior decisions, the majority said allowing full consideration of mitigation satisfies the Eighth Amendment’s demand for individualized sentencing and that the Constitution does not require juries to further refine or weigh the strength of an aggravating factor.

Real world impact

The ruling lets Pennsylvania juries impose death where a single aggravator and no mitigators are found, if the jury so determines. It makes presenting mitigating evidence important for defendants who want to avoid a mandatory death outcome. The decision affirms that States may structure capital-sentencing procedures within the Court’s Eighth Amendment framework.

Dissents or concurrances

Justice Brennan, joined by Justice Marshall and others in part, dissented. He argued the statute’s mandatory clause substitutes the legislature’s judgment for the jury’s moral judgment, denies a truly individualized sentencing decision, and wrongly prevents juries from weighing how serious an aggravating circumstance really is. He would have found the statute unconstitutional and would not have sustained Blystone’s death sentence.