Bell v. Cone

PETITIONER: Bell
RESPONDENT: Cone
LOCATION: Texas State Capitol

DOCKET NO.: 04-394
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 543 US 447 (2005)
DECIDED: Jan 24, 2005

Facts of the case

In 1984 a Tennessee court sentenced Cone to death for murder. The jury had found four aggravating circumstances, one of which was that the murder was "especially heinous, atrocious, or cruel." Cone's state appeals were unsuccessful. A federal district court then rejected Cone's habeas petition. The Sixth Circuit reversed. The U.S. Supreme Court reversed the Sixth Circuit's ruling in Bell v. Cone (2002). On remand, the Sixth Circuit again reversed Cone's sentence on the ground that the "especially heinous, atrocious, or cruel" aggravator was unconstitutionally vague under the Eighth Amendment.

Question

A Tennessee law made it an aggravating circumstance during sentencing if a murder had been "especially heinous, atrocious, or cruel." Did the state supreme court interpret that sufficiently narrowly, so that it did not run afoul of the Eighth Amendment?