Sattazahn v. Pennsylvania

Background

A man, David Allen Sattazahn, was tried in Pennsylvania for a murder committed during a robbery. After a guilty verdict the trial moved to a penalty phase. The jury deadlocked 9–3 in favor of life, and under Pennsylvania law the judge entered a mandatory life sentence. The first conviction was later reversed on appeal, Pennsylvania retried him, sought the death penalty again, and the second jury imposed death. The Pennsylvania Supreme Court upheld retrying the death question, and the U.S. Supreme Court reviewed that ruling.

Reasoning

The central question was whether the mandatory life sentence entered after the hung penalty jury stopped the State from trying the death question again. The Court applied its double-jeopardy cases (including the line treating a true “acquittal” of death as final) and recent decisions about when facts that increase punishment must be treated as elements. The Court concluded the hung jury and the judge’s statutory entry of life involved no factual findings that amounted to an acquittal of the aggravating facts needed for death. Because neither jury nor judge made findings establishing entitlement to life, double-jeopardy did not bar retrying the death penalty.

Real world impact

States with similar sentencing rules may re-seek the death penalty after a deadlocked sentencing jury and a statutory life entry. Capital defendants therefore risk facing a death retrial if an earlier conviction is later set aside. The ruling rests on detailed distinctions about when a life judgment is an "acquittal" rather than on the mere existence of a life sentence.

Dissents or concurrances

Justice O'Connor joined the judgment but not the Court’s extension of the Apprendi/Ring reasoning. Justice Ginsburg (joined by three Justices) dissented, arguing the statutory life judgment was final and should bar retrial.