Williams v. Ohio

Background

People sentenced to death in cases from Ohio and Alabama challenged their sentences. The petitions say the laws used to justify the death penalty relied on statutory aggravating factors that repeat elements of the underlying capital offenses. The Ohio Supreme Court rejected one challenge, and the Supreme Court issued a short entry: certiorari was denied, so the high Court declined to take these cases for review.

Reasoning

The core question was whether a death sentence may be based on an aggravating factor that merely duplicates part of the criminal offense and thus fails to narrow who is eligible for death. The Supreme Court did not decide that constitutional question because it refused to hear the cases. Several Justices dissented from the denial: Justice White (joined by Justice Brennan in one case) said the Court should resolve conflicting lower-court rulings; Justice Marshall referenced his views in Wiley v. Mississippi; Justice Brennan said he would vacate the death sentences because he regards the death penalty as always unconstitutional.

Real world impact

Because the Court declined review, the lower-court rulings remain in effect for these cases and the death sentences at issue stand for now. The legal dispute over whether repeating aggravating factors are permissible remains unsettled and the conflicting rulings among lower courts continue. This decision is not a merits ruling and the constitutional issue could be resolved differently if the Court later accepts a similar case.

Dissents or concurrances

Three Justices wrote separate dissents: Marshall and White would have granted review to address the issue, and Brennan would have granted review and vacated the death sentences, stating his view that the death penalty is cruel and unusual punishment.