LOCATION: Superior Court of Maricopa County, Southeast Facility
DOCKET NO.: 15-8366
DECIDED BY: Roberts Court (2016- )
LOWER COURT: Arizona Supreme Court
CITATION: 578 US (2016)
GRANTED: May 31, 2016
DECIDED: May 31, 2016
Facts of the case
Shawn Patrick Lynch was convicted of first-degree murder, kidnapping, armed robbery and burglary, with all the charges stemming from the 2001 kidnapping and murder of James Panzarella. Arizona sought the death penalty and moved to prevent Lynch’s counsel from informing the jury that the only alternative to sentence to death was life without parole. The trial court granted the motion, and after the first jury failed to reach a unanimous verdict, the second jury sentenced Lynch to death. Lynch appealed and argued that, by granting Arizona’s motion, the trial court had violated Lynch’s Due Process Clause rights under the Supreme Court’s precedent in Simmons v. South Carolina. In that case, the Supreme Court established that, when a capital defendant’s future dangerousness is at issue and the only alternative to the death penalty is life imprisonment without the possibility of parole, the Due Process Clause grants the defendant the right to inform the jury of his ineligibility for parole. The Supreme Court of Arizona vacated the sentence without addressing the Simmons argument, and on remand the jury again sentenced Lynch to death. Lynch again appealed and raised the Simmons argument, which the Supreme Court of Arizona rejected by holding that the failure to inform the jury of Lynch’s parole ineligibility was not error.
When the only alternative to the death penalty is life imprisonment without the possibility of parole and the defendant’s future dangerousness has been raised as an issue, does the failure to inform the jury of a capital defendant’s ineligibility for parole violate the defendant’s due process rights?