Espinosa v. Florida

Background

A Florida jury found Henry Jose Espinosa guilty of first-degree murder and recommended death after the trial judge instructed the jury that the murder could be considered an aggravating factor if it was "especially wicked, evil, atrocious or cruel." The trial court then weighed aggravating and mitigating factors, imposed death, and the Florida Supreme Court upheld the sentence despite Espinosa’s challenge that the jury instruction was vague.

Reasoning

The Court addressed whether a vague aggravating-factor instruction violates the Eighth Amendment when the jury’s sentencing recommendation is given great weight by the trial court. The Court explained that in States that require weighing aggravating and mitigating factors, an invalid (vague) aggravating circumstance may not be counted. Because Florida gives "great weight" to the jury’s recommendation, the jury’s likely consideration of a vague factor would be indirectly weighed by the judge, creating the same risk of arbitrary death sentences. For that reason the Court reversed the Florida decision and sent the case back for further proceedings.

Real world impact

The ruling means courts in Florida (and similar schemes) must ensure jury instructions on aggravating factors are clear so juries do not consider vague factors that could sway a death sentence. Affected defendants may obtain new sentencing review or further proceedings if similar instructions were used. The decision was issued summarily rather than after full oral argument, but it nonetheless requires clearer guidance in capital cases.

Dissents or concurrances

Justice Scalia dissented, arguing the sentence met the Constitution’s narrowing requirement and he would have denied relief; the Chief Justice and Justice White also dissented, preferring to hear the case in full with oral argument.