Bobby v. Mitts

Background

Harry Mitts, an Ohio defendant convicted of two aggravated murders and two attempted murders, was sentenced to death. The dispute centered on the jury instructions used during the penalty phase, which told jurors they must find beyond a reasonable doubt that aggravating factors outweighed mitigating factors to recommend death, and otherwise choose between two life terms. The Sixth Circuit vacated the death sentence, concluding the instructions violated a prior Supreme Court rule about unfair all-or-nothing choices for juries.

Reasoning

The Court considered whether those penalty-phase instructions were contrary to the Supreme Court’s earlier decisions and whether federal habeas relief was available under the strict review rules of AEDPA. The Justices explained that the key concern from the earlier case (Beck) was about forcing juries in the guilt phase to choose between capital conviction and complete acquittal, a risk not present here because the jurors had already convicted Mitts. The Court relied on a recent decision addressing the same Ohio instructions and held that the instructions were not contrary to clearly established Supreme Court law, so the federal-court vacatur could not stand under AEDPA.

Real world impact

The result reverses the appeals court and rejects the specific claim that these penalty-phase instructions violate the Constitution as clearly established law. Practically, the ruling limits the ability of people on death row to win federal habeas relief based on the same kind of jury instructions, and it affirms that courts must apply AEDPA’s narrow standards when reviewing such claims.

Dissents or concurrances

The opinion notes that a separate Justice in an earlier case would have invalidated the instructions, but the Court’s majority rejected that approach and applied AEDPA to deny relief here.