Patterson v. South Carolina

Background

Two men on death row (Koon and Patterson) had been resentenced in South Carolina and sought to present evidence that they adapted well to prison and would likely be nondangerous if incarcerated. Their lawyers offered prison officials’ testimony and psychiatric opinions about the men’s likely safe adjustment to prison life as reasons for a lighter sentence. The state trial court excluded that proof, and the South Carolina Supreme Court affirmed the exclusion as legally irrelevant.

Reasoning

The core question was whether evidence that a defendant would probably be nondangerous in prison is a valid reason for a jury to impose life instead of death. Justice Marshall’s dissent argues that past Supreme Court decisions require sentencers to consider any mitigation the defendant offers and that predicting future dangerousness has long been treated as relevant. He says the state court’s rule — that prison nondangerousness is irrelevant because it does not increase or decrease moral blame for the crime — conflicts with those precedents.

Real world impact

Because the Supreme Court declined to review these cases, the South Carolina rulings excluding prison-adaptability and nondangerousness evidence remain in place for these defendants. That means juries in these cases were not allowed to hear or weigh those specific kinds of mitigating proof. Justice Marshall warned this approach could encourage other state courts to narrow what counts as mitigation, reducing what juries may consider in capital sentencing.

Dissents or concurrances

Justice Marshall, joined by Justice Brennan, dissented from the denial of review and would have granted the petitions, emphasizing the Eighth Amendment concerns and the need to respect prior decisions requiring broad consideration of mitigating evidence.