Lynch v. Arizona

Background

Shawn Patrick Lynch, convicted of first-degree murder and related crimes in Arizona, faced three separate penalty-phase juries and was sentenced to death. Before his third penalty trial, the trial court barred defense counsel from telling the jury that Arizona law made him ineligible for parole. The Arizona Supreme Court rejected Lynch's Simmons-based claim and affirmed his sentence, and the U.S. Supreme Court agreed to review and decide the issue.

Reasoning

The Court addressed whether due process requires allowing a capital defendant to inform a jury he cannot be paroled when the prosecution raises the defendant's future dangerousness and the only alternative to death is life without parole. Applying Simmons and related precedents, the majority found that Arizona law made Lynch parole ineligible at the time of trial and held that the defendant is entitled to inform the jury of that fact. The Court rejected Arizona's arguments that clemency or possible future legislative change undermined that entitlement.

Real world impact

The ruling means trial judges in similar death-penalty cases must permit juries to be told when a defendant is ineligible for parole if future dangerousness is a contested issue. The Court reversed and remanded for further proceedings consistent with its opinion, so remedies may include new jury instructions or additional hearings.

Dissents or concurrances

Justice Thomas, joined by Justice Alito, dissented, arguing the trial judge's instruction already described Arizona law adequately, that Simmons was wrongly decided, and that the Court overreached by demanding a more explicit parole-ineligibility statement.