Tuggle v. Netherland

PETITIONER: Tuggle
RESPONDENT: Netherland
LOCATION: Eastern District Court of Michigan

DOCKET NO.: 95-6016
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Fourth Circuit

CITATION: 516 US 10 (1995)
DECIDED: Oct 30, 1995

Facts of the case

Lem Tuggle was convicted of murder. After the Commonwealth presented unrebutted psychiatric testimony of his future dangerousness, the jury found two statutory aggravating circumstances and sentenced Tuggle to death. Subsequently, the U.S. Supreme Court remanded the case under Ake v. Oklahoma, 470 U.S. 68, which held that when the prosecution presents psychiatric evidence of an indigent defendant's future dangerousness in a capital sentencing proceeding, due process requires the State to provide the defendant with the assistance of an independent psychiatrist. On remand, the State Supreme Court invalidated the future dangerousness aggravating factor, but upheld the death sentence based on the vileness aggravator under Zant v. Stephens, 462 U.S. 862. Agreeing, the Court of Appeals construed Zant as establishing a rule that in nonweighing States a death sentence may be upheld based on one valid aggravating circumstance, regardless of the reasons for finding another aggravating factor invalid.

Question

Did the Court of Appeals correctly interpret Zant v. Stephens, 462 U.S. 862, to establish a rule that, in States that do not weigh aggravating circumstances against mitigating circumstances, a death sentence may be upheld on the basis of one valid aggravating circumstance, regardless of the reasons for which another aggravating factor may have been found to be invalid?