White v. Maryland

Background

A person convicted in Maryland was sentenced to death under a state law that requires the death penalty whenever mitigating circumstances do not outweigh aggravating circumstances. The Maryland Court of Appeals left the death sentence in place, and the United States Supreme Court declined to take the case, formally refusing review.

Reasoning

The central question was whether the Maryland statute that forces a death sentence in those circumstances is constitutional and whether the Supreme Court should hear that challenge. Justice Marshall, joined by Justice Brennan, wrote a dissent from the Court’s refusal to hear the case. Marshall explained that he believes the death penalty is always barred as cruel and unusual punishment and that, even if the death penalty could be allowed sometimes, this particular law is unconstitutional because it gives the jury no room to decide whether death is an appropriate punishment in the individual case.

Real world impact

Because the Court refused review, the death sentence remains undisturbed for the person in this case and the Maryland statute continues to operate. The denial is not a decision on the merits, so the constitutional question about mandatory death sentences was not finally resolved by the Supreme Court and could be raised again in a future case. The outcome directly affects people sentenced under similar state statutes and leaves unresolved whether such laws must allow juries to weigh appropriateness.

Dissents or concurrances

Justice Marshall’s dissent emphasizes two points: he views the death penalty as unconstitutional in all circumstances, and he contends this statute’s mandatory rule is unconstitutional because it removes jury discretion.