Quick Summary
McCleskey (the murderer) was sentenced to death for armed robbery and murder. He then filed a writ of habeas corpus with the federal district court, alleging that Georgia’s death penalty procedure discriminated against people of different races in violation of the Eighth and Fourteenth Amendments to the Constitution.
McCleskey presented statistics to prove his discrimination claim. The district and appeals courts denied both suits, but USSC granted certiorari.
The Supreme court ruled that the statistics don’t establish racial bias. It does not give enough evidence to determine that the jury in his case engaged in purposeful racial discrimination, as required by the Equal Protection Clause.
Rule of Law
A plaintiff alleging a breach of equal protection must show intentional discrimination on the defendant’s part. Likewise, a criminal defendant must show that he has been discriminated against due to intentional prejudice.
Facts of the Case
McCleskey (plaintiff), an African American guy, was found guilty of armed robbery and killing a white police officer in Atlanta, Georgia. The jury recommended that he be given two separate life sentences for armed robbery and the death penalty for murder. The court adopted this directive, and McCleskey was sentenced to death.
The federal district court received a writ of habeas corpus from McCleskey stating that Georgia’s death penalty process discriminated against people of different races, violating the Eighth and Fourteenth Amendments of the United States Constitution.
McCleskey used statistical analysis to back up his claim that there was a difference in race between the murder victim and the individual sentenced to death in Georgia. For instance, a defendant who killed a Caucasian victim received a death sentence 22 times more often than a victim of African American descent. The poll also showed that Caucasian defendants were far less likely than African Americans to receive a death sentence. The federal district court and the Court of Appeals denied McCleskey’s claim. The Supreme Court of the United States granted certiorari.
Issue
Does the defendant’s racial discrimination under Georgia’s death sentence legislation violate the Fourteenth Amendment’s Equal Protection Clause?
Holding and Conclusion
No.
The study that the defendant presented does not show that racial bias was a reason why the defendant himself got the death penalty. Moreover, the analysis does not provide sufficient evidence to conclude that the jury in his case engaged in intentional racial discrimination, which is necessary for establishing a violation of the Equal Protection Clause.
Comprehensive statistical research showing that a state’s death penalty laws are enforced in a way that makes it more likely for black murderers who kill white people to get the death penalty was not enough to prove the kind of unfair impact the defendant was expecting. The court held that policies against racial bias on juries, jury trials in general, and trial procedures were enough to protect defendants’ rights.
Reasoning and Analysis
Suppose a defendant wants to challenge his sentence on the grounds of discrimination. In that case, the court says he or she must provide evidence of actual bias in this particular case, not just statistical evidence showing disparities in sentencing based on race. Similarly, the Eighth Amendment does not prohibit “cruel and unusual” punishments because of the likelihood of racial bias informing a juror’s judgment on a defendant’s sentence.
The court ruled that there is a racial disparity in giving the death sentence in a given state, but this does not mean that capital punishment is unconstitutional under the Eighth Amendment unless there is evidence of racial discrimination on the part of the state.
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