ROBERTS v. LOUISIANA
Following his conviction for first-degree murder, and subsequent imposition of a death sentence, Roberts challenged the constitutionality of Louisiana's death penalty scheme. This scheme mandated the death penalty's imposition, regardless of any mercy recommendation, whenever the jury found that the defendant demonstrated a specific intent to kill or inflict great bodily harm while in the commission of at least one of five different narrowly defined types of homicide. The sentencing scheme also required juries, in all first- degree murder cases, to be instructed on the lesser charges of manslaughter and second degree murder even if no evidence existed to support such verdicts.
Does Louisiana's death-penalty sentencing scheme violate the Eighth and Fourteenth Amendments' safeguards against arbitrary and capricious death penalty impositions?
Legal provision: Amendment 8: Cruel and Unusual Punishment
Yes. By mandating the death penalty's imposition for certain crimes, Louisiana's sentencing scheme fails to afford juries the constitutionally required opportunity to consider any mitigating factors presented either by the circumstances of the crime or the individual offender's character. The Supreme Court also held that by requiring jurors to be instructed on the lesser charges of manslaughter and second-degree murder, even if no evidence exits to support such verdicts, Louisiana's sentencing scheme encourages them to disregard their oaths by recommending a verdict for a lesser offense whenever they feel that the death penalty is inappropriate.