Tison v. Arizona Case Brief

Why is the case important?

The Petitioners, Ricky and Raymond Tison (Petitioners), were sentenced by a judge to death after conviction for four murders under accomplice liability and felony-murder statutes. Neither of the Petitioners actually committed the murders himself, but rather, the deaths were caused by their co-felons, in the course of an armed robbery, kidnapping and car theft.

Facts of the case

“Ricky and Raymond Tison, brothers, conspired with several other family members to help their father, Gary, escape from prison. Gary was serving life in prison for murdering a guard during a previous escape attempt. Smuggling in a cooler full of guns, the Tisons helped Gary and his cellmate Randy escape. The group made a safe exit, but a few days later their car got a flat tire. They decided to flag down and steal a passing car. The group ordered the family of four out of the car while they transferred their belongings. When Ricky and Raymond went to get the family some water, Gary and Randy shot the family multiple times, killing them all. Ricky and Raymond did nothing to help the family. They continued to run with Randy and Gary until the chase ended in a shootout with police. Gary died in the desert of exposure before the police found him, and another brother died in the shootout. Ricky, Raymond, and Randy faced four counts of felony murder through accomplice liability. All three received the death penalty.The Supreme Court of Arizona affirmed the sentences, holding that while the Tisons had not specifically intended to kill the family, they conspired with known killers and did nothing to aid the family when they had the chance. The Court held that the son’s anticipation that lethal force might be used in their endeavor satisfied the “intent” requirement for the death penalty.”

Question

Does the Eighth Amendment of the United States Constitution (Constitution) prohibit the death penalty where the defendant participated substantially in the crime, but whose mental state is one of reckless indifference to the value of human life, rather than a mental state reflecting an intent to kill?

Answer

No. The Petitioners aided in bringing an arsenal of lethal weapons to a prison in order to arm two convicted murderers for the purpose of escaping. The Petitioner Raymond Tison performed the role of flagging down the victims, robbed the victims and guarded them at gunpoint. He then watched the killing without making an effort to assist the victims. The Petitioner Ricky Tison’s behavior was substantially the same. This conduct evidences a substantial participation in the crime and a reckless disregard for the value of human life. The reckless disregard for human life implicit in knowingly engaging in criminal activities known to carry a grave risk of death represents a highly culpable mental state, a mental state that may be taken into account in making a capital sentencing judgment when that conduct causes its natural, though also not inevitable, lethal result.

Conclusion

“The Court found that the state supreme court applied an erroneous standard to reach its holding. The Court found the state supreme court tried to include the element of foreseeability in the “”intent to kill”” when it found that the prisoner, the petitioners’ father, intended to kill the victims. The Court concluded that petitioners did not fall within the “”intent to kill”” category. Therefore, the Court found the death sentence to be disproportionate to the crime of armed robbery committed by petitioners. The Court vacated the lower court’s decision and remanded the case.”

  • Case Brief: 1987
  • Petitioner: Ricky and Ramond Tison
  • Respondent: Arizona
  • Decided by: Rehnquist Court

Citation: 481 US 137 (1987)
Argued: Nov 3, 1986
Decided: Apr 21, 1987
Granted Feb 24, 1986