Shafer v. South Carolina
Encyclopedia
Shafer v. South Carolina, 532 U.S. 36 (2001), was a United States Supreme Court
case decided in 2001. The case concerned the ability of a defendant to tell the jury that, absent a penalty of death, a penalty of life imprisonment would not permit early release of a prisoner on parole. While the question had been decided in the case of Simmons v. South Carolina, this case dealt with the extent of the ruling.
requires that the jury be informed of the defendant's parole ineligibility. The state of South Carolina
had changed its sentencing laws in the succeeding years to include the actual possibility of parole in absence of the death penalty, after sentencing questions were answered by the jury.
In the late Fall of 1997, Wesley Aaron Shafer, Jr., was found guilty of, inter alia
, murder. During the sentencing phase, Shafer's counsel argued that Simmons required the trial judge to instruct the jury that under South Carolina law, a life sentence carries no possibility of parole
. The prosecution responded that because the state did not plan to argue to the jury that Shafer would be a danger in the future, no Simmons instruction
was required. During deliberations, the jury asked under what conditions someone convicted of murder could become available for parole. The trial judge stated that parole eligibility or ineligibility was not a matter for the jury's consideration. Ultimately, the jury recommended the death penalty and the judge imposed the sentence. In affirming, the South Carolina Supreme Court
held that Simmons generally did not apply to the State's sentencing scheme because an alternative to death other than life without the possibility of parole existed.
wrote the Opinion of the Court, which reversed the decision of the South Carolina Supreme Court, finding in favor of Shafer. She wrote that "whenever future dangerousness is at issue in a capital sentencing proceeding under South Carolina's new scheme, due process requires that the jury be informed that a life sentence carries no possibility of parole." She continued with this line of thinking, explaining "[i]t is only when the jury endeavors the moral judgment whether to impose the death penalty that parole eligibility may become critical. Correspondingly, it is only at that stage that Simmons comes into play, a stage at which South Carolina law provides no third choice, no 30-year mandatory minimum, just death or life without parole." Therefore, South Carolina's actions violated Shafer's Due Process rights, and the case was sent back for renewed sentencing determinations.
wrote a brief dissent from the majority's decision. He agreed that under Simmons, Shafer would probably have to have a new chance at sentencing; instead, he argued that this new criminal rule made by the courts was not proper for the American system of jurisprudence.
Justice Clarence Thomas
wrote a separate dissent in the same lines as Scalia's. He also agreed that the majority decision was the "next logical step of Simmons" However, he argued that the instructions by the judge in this case were adequate under the standards set forth by the Court. He reasoned that the jury clearly understood what the two possibilities were, and thus no due process violation had occurred.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case decided in 2001. The case concerned the ability of a defendant to tell the jury that, absent a penalty of death, a penalty of life imprisonment would not permit early release of a prisoner on parole. While the question had been decided in the case of Simmons v. South Carolina, this case dealt with the extent of the ruling.
Background
In 1994, the United States Supreme Court decided the case of Simmons v. South Carolina. The U.S. Supreme Court held in this case that where a capital defendant's future dangerousness is at issue, and the only sentencing alternative to death available to the jury is life imprisonment without possibility of parole, due processDue process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
requires that the jury be informed of the defendant's parole ineligibility. The state of South Carolina
South Carolina
South Carolina is a state in the Deep South of the United States that borders Georgia to the south, North Carolina to the north, and the Atlantic Ocean to the east. Originally part of the Province of Carolina, the Province of South Carolina was one of the 13 colonies that declared independence...
had changed its sentencing laws in the succeeding years to include the actual possibility of parole in absence of the death penalty, after sentencing questions were answered by the jury.
In the late Fall of 1997, Wesley Aaron Shafer, Jr., was found guilty of, inter alia
Inter Alia
-Track listing:# Inter Alia# Outfox'd # Righteous Badass # The Altogether feat. Bix, Apt, UNIVERSE ARM and Cal# The Day-to-Daily# Trouble Brewing # The Prestidigitator# The Force...
, murder. During the sentencing phase, Shafer's counsel argued that Simmons required the trial judge to instruct the jury that under South Carolina law, a life sentence carries no possibility of parole
Parole
Parole may have different meanings depending on the field and judiciary system. All of the meanings originated from the French parole . Following its use in late-resurrected Anglo-French chivalric practice, the term became associated with the release of prisoners based on prisoners giving their...
. The prosecution responded that because the state did not plan to argue to the jury that Shafer would be a danger in the future, no Simmons instruction
Jury instructions
Jury instructions are the set of legal rules that jurors should follow when the jury is deciding a civil or criminal case. Jury instructions are given to the jury by the jury instructor, who usually reads them aloud to the jury...
was required. During deliberations, the jury asked under what conditions someone convicted of murder could become available for parole. The trial judge stated that parole eligibility or ineligibility was not a matter for the jury's consideration. Ultimately, the jury recommended the death penalty and the judge imposed the sentence. In affirming, the South Carolina Supreme Court
South Carolina Supreme Court
The South Carolina Supreme Court is the highest court in the U.S. state of South Carolina. The court is composed of a Chief Justice and four Associate Justices.-Selection of Justices:...
held that Simmons generally did not apply to the State's sentencing scheme because an alternative to death other than life without the possibility of parole existed.
Opinion of the Court
Justice Ruth Bader GinsburgRuth Bader Ginsburg
Ruth Joan Bader Ginsburg is an Associate Justice of the Supreme Court of the United States. Ginsburg was appointed by President Bill Clinton and took the oath of office on August 10, 1993. She is the second female justice and the first Jewish female justice.She is generally viewed as belonging to...
wrote the Opinion of the Court, which reversed the decision of the South Carolina Supreme Court, finding in favor of Shafer. She wrote that "whenever future dangerousness is at issue in a capital sentencing proceeding under South Carolina's new scheme, due process requires that the jury be informed that a life sentence carries no possibility of parole." She continued with this line of thinking, explaining "[i]t is only when the jury endeavors the moral judgment whether to impose the death penalty that parole eligibility may become critical. Correspondingly, it is only at that stage that Simmons comes into play, a stage at which South Carolina law provides no third choice, no 30-year mandatory minimum, just death or life without parole." Therefore, South Carolina's actions violated Shafer's Due Process rights, and the case was sent back for renewed sentencing determinations.
Dissenting opinions
Justice Antonin ScaliaAntonin Scalia
Antonin Gregory Scalia is an American jurist who serves as an Associate Justice of the Supreme Court of the United States. As the longest-serving justice on the Court, Scalia is the Senior Associate Justice...
wrote a brief dissent from the majority's decision. He agreed that under Simmons, Shafer would probably have to have a new chance at sentencing; instead, he argued that this new criminal rule made by the courts was not proper for the American system of jurisprudence.
Justice Clarence Thomas
Clarence Thomas
Clarence Thomas is an Associate Justice of the Supreme Court of the United States. Succeeding Thurgood Marshall, Thomas is the second African American to serve on the Court....
wrote a separate dissent in the same lines as Scalia's. He also agreed that the majority decision was the "next logical step of Simmons" However, he argued that the instructions by the judge in this case were adequate under the standards set forth by the Court. He reasoned that the jury clearly understood what the two possibilities were, and thus no due process violation had occurred.