Arave v. Creech Case Brief

Facts of the Case

“After respondent Creech pleaded guilty to first-degree murder for the brutal slaying of a fellow Idaho prison inmate, the state trial judge sentenced him to death, based in part on the statutory aggravating circumstance that “by the murder, or circumstances surrounding its commission, the defendant exhibited utter disregard for human life.” In affirming, the Idaho Supreme Court, among other things, rejected Creech’s argument that this aggravating circumstance is unconstitutionally vague and reaffirmed the limiting construction it had placed on the statutory language in, whereby,, “‘the phrase “utter disregard”… is meant to be reflective of … the cold-blooded, pitiless slayer.'” Although the Federal District Court denied habeas corpus relief, the Court of Appeals found the “utter disregard” circumstance facially invalid, holding, among other things, that the circumstance is unconstitutionally vague and that thenarrowing construction is inadequate to cure the defect under this Court’s precedents.”


May an employer be held liable under Title VII of the Civil Rights Act of 1964 for the acts of an employee whose sexual harassment of subordinates has created a hostile work environment amounting to employment discrimination?



Case Information

Citation: 507 US 463 (1993)
Argued: Nov 10, 1992
Decided: Mar 30, 1993
Case Brief: 1993