Bobby v. Mitts
131 S. Ct. 1762
| SCOTUS | 2011Background
- Mitt s was convicted in Ohio of two counts of aggravated murder and two counts of attempted murder and sentenced to death.
- During the penalty phase, the jury was instructed that if aggravating factors outweighed mitigating factors, they must recommend death; otherwise they would select from two life-imprisonment options.
- The Sixth Circuit vacated Mitt s’s death sentence, ruling the instructions were contrary to Beck because they perceived an acquittal-first framework urging life options only after a deemed death verdict.
- The case analyzed prior related decisions, notably Mills and Beck, and referenced Spisak v. Mitchell and AEDPA 28 U.S.C. § 2254(d)(1) standard for determining if state court decisions were based on clearly established federal law.
- The Supreme Court held Beck’s concerns about an all-or-nothing guilt determination do not govern penalty-phase proceedings, and that the Ohio instructions were not contrary to clearly established federal law under AEDPA.
- The Court reversed the Sixth Circuit’s judgment, reinstating Mitt s’s death sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do the penalty-phase instructions violate Beck v. Alabama? | Mitt s argues the instructions create an acquittal-first coercion toward death. | Bobby contends Beck is not applicable to penalty-phase deliberations. | No, Beck does not govern penalty-phase; not contrary to clearly established law. |
| Does AEDPA foreclose relief based on Spisak and related precedent? | Mitt s claims the court should apply Beck-based concerns under AEDPA. | State argues Spisak controls; Beck-based error not clearly established. | AEDPA does not require relief; decision not contrary to clearly established federal law. |
Key Cases Cited
- Beck v. Alabama, 447 U.S. 625 (1980) (death-penalty scheme cannot compel all-or-nothing choice between capital conviction and innocence)
- Mills v. Maryland, 486 U.S. 367 (1988) (guilt-phase standards regarding capital punishment)
- Schad v. Arizona, 501 U.S. 624 (1991) (penalty-phase considerations and deliberations)
- California v. Ramos, 463 U.S. 992 (1983) (distinction between guilt determination and penalty deliberations)