Eddings v. Oklahoma

PETITIONER: Monty Lee Eddings
RESPONDENT: Oklahoma
LOCATION: Turner Turnpike

DOCKET NO.: 80-5727
DECIDED BY: Burger Court (1981-1986)
LOWER COURT: Oklahoma Court of Criminal Appeals

CITATION: 455 US 104 (1982)
ARGUED: Nov 02, 1981
DECIDED: Jan 19, 1982
GRANTED: Apr 06, 1981

ADVOCATES:
David W. Lee - on behalf of the Respondent
Jay C. Baker - on behalf of the Petitioner

Facts of the case

On April 4, 1977, Monty Lee Eddings, who was sixteen-year-old, together with his friends escaped from home. Before the departure, he stole three of his father`s guns. Firstly the drove to the Howard Johnson restaurant to visit it. While departing from the place, Eddins became irate and drove the car out to brake. The person who became the witness to this accident call to police to testify the facts.

Larry Crabtree, the officer of patrolling police, began to chase them, Eddings started to shot putting the gun forward the window and injured deadly Crabtree. But he slipped away from the place of the murder.

During the hearing, the defender’s side submitted facts that allegedly could mitigate the guild of the offender. It was the difficult circumstances of his childhood as when he had five his parents had divorced, and this event impacted negatively on his health as he had no permanent place of living straggling from mother`s to father`s house. Also, witnesses gave testimonies that the defender had not enough and not healthy psychological development as he would have at his age. After that, a state psychologist confirmed that Eddings suffered from a sociopathic personality disorder.

The state defender claimed regarding the irritating circumstances as that the offense was especially atrocious or vicious, was committed with intent to prevent legible arrest and the defender threatened for public interests.

The judge decided that the prosecutor proved all three aggravating circumstances were more significant than the mitigating ones and proved guilty of the offender. The decision imposed the death imprisonment, and the Court of Criminal Appeals confirmed the punishment in the case of Eddings vs. Oklahoma

Then the defender appealed to the High Court of the USA to complain that his rights under the Eight and Fourteen Amendments were infringed.

After hearings, the court ordered that the previous judgment in Eddings v. Oklahoma was approved with the breach of hos constitution guarantees. Especially, that any circumstances that could be mitigating to be considered with reasonable doubt. But the judge determined that the appeal and district courts didn`t recognize these facts due.

The final ruling underlined that the medical conclusions that the physiological development was not relevant to the 16-year-old offender and all these reasons were legally grounded. Therefore, the imposed punishment in Eddings v Oklahoma had to be reviewed, and the decision should change as it violated the rights under the Eighth and Fourteenth Amendments.

Question

Did the trial court commit a plain error when it failed to consider evidence of Eddings’ unhappy childhood and emotional disturbance in its consideration of mitigating and aggravating circumstances?

Media for Eddings v. Oklahoma

Audio Transcription for Oral Argument - November 02, 1981 in Eddings v. Oklahoma

Audio Transcription for Opinion Announcement - January 19, 1982 in Eddings v. Oklahoma

Warren E. Burger:

The judgment and opinion of the Court in Eddings against Oklahoma will be announced by Justice Powell.

Lewis F. Powell, Jr.:

This is a capital case here on certiorari to the Court of Appeals -- Court of Criminal Appeals of Oklahoma.

When Eddings was 16 years old, he shot and killed a state highway patrol officer at the time Eddings, with three younger juveniles, was running away from their Missouri homes.

He had a history of emotional problems, had been raised in a difficult family situation, and there was testimony that his mental and emotional development were at a level several years below his chronological age.

The Oklahoma capital punishment statute provides in the sentencing proceeding that evidence may be presented as to mitigating and aggravating circumstances.

Eddings' age was considered as a mitigating circumstance but this was viewed as outweighed by aggravating circumstances primarily the deliberate shooting of a state officer without provocation other than the fact that Eddings have been stopped on a state highway for erratic driving.

Although the trial court admitted evidence as to Eddings' family history and emotional instability, it declined to consider these as mitigating circumstances.

The Court of Criminal Appeals agreed and a sentence of death was affirmed.

In Lockett against Ohio, we held that the Eighth and Fourteenth Amendments require in a capital case that the sentencing authority not be precluded from considering, as a mitigating factor, any aspect of a defendant's character or record.

We think the Oklahoma Court's committed error in failing to consider Eddings' background in mitigation.

We therefore reverse the judgment insofar as it imposed the death penalty and remand the case for further proceedings.

This Court is not unaware of the extent of which minors engage increasingly in violent crime nor do we suggest an absence of legal responsibility where crime is committed by a minor.

We are concerned in this case only with the validity of the procedure by which the death sentence was imposed on an emotionally disturbed 16-year-old.

Justices Brennan and O'Connor have filed concurring opinions.

The Chief Justice has filed a dissenting opinion in which Justices White, Blackmun, and Rehnquist have joined.

Warren E. Burger:

Thank you Justice Powell.