Lynch v. Arizona
136 S. Ct. 1818
| SCOTUS | 2016Background
- Shawn Patrick Lynch was convicted of first-degree murder and related offenses for a 2001 killing; the State sought death.
- At penalty phase the trial court barred defense counsel from telling the jury that the only nondeath sentence available to Lynch would be life without parole (LWOP).
- Lynch’s first penalty jury hung; a later jury sentenced him to death; after an intermediate reversal and a third penalty jury again sentenced him to death.
- Arizona law abolished parole for felonies committed after Jan 1, 1994, so Lynch (2001 offense) was ineligible for parole; the State conceded any early-release mechanism would be executive clemency only.
- The Arizona Supreme Court acknowledged Lynch’s parole ineligibility and that the State argued future dangerousness, but held Simmons did not require informing the jury of parole ineligibility.
- The U.S. Supreme Court reversed, holding Simmons and its progeny entitle a capital defendant to inform the jury of parole ineligibility when future dangerousness is at issue and LWOP is the only alternative to death.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether due process required informing the jury that Lynch was parole ineligible when future dangerousness was argued | Lynch: Due process under Simmons entitles him to inform the jury of parole ineligibility to rebut future-dangerousness arguments | Arizona: State argued Simmons applies only where parole is legally impossible and that future legislative change or clemency could make release possible | Court: Reversed Arizona; Simmons applies — when future dangerousness is at issue and LWOP is the only alternative, defendant may inform the jury of parole ineligibility |
| Whether possibility of executive clemency or future legislative change defeats Simmons protection | Lynch: Clemency or hypothetical future changes do not undermine the right to inform the jury of current parole ineligibility | Arizona: Legislature could reinstate parole or clemency could allow release, so no categorical bar to informing jury | Court: Rejected Arizona’s argument; Simmons and Ramdass hold current, conclusive parole ineligibility controls, not speculative future changes |
| Whether a trial instruction describing life options (including "life with possible release after 25 years" vs "natural life") satisfied Simmons | Lynch: Jury must be told that any "possible release" does not include parole under current law | Arizona: Accurate recitation of sentencing options sufficed; no need to specify parole ineligibility | Court: Instruction that fails to inform jury of parole ineligibility when LWOP is the only real alternative is insufficient under Simmons |
| Scope of Simmons and its progeny for state sentencing schemes differing from earlier cases | Lynch: Simmons governs where defendant conclusively shows parole ineligibility and the prosecution puts dangerousness at issue, regardless of state sentencing particulars | Arizona: Arizona’s sentencing regime (statutory distinctions and clemency only) makes Simmons inapplicable | Court: Simmons governs; Arizona’s factual statutory differences do not excuse failure to allow jury knowledge of parole ineligibility |
Key Cases Cited
- Simmons v. South Carolina, 512 U.S. 154 (1994) (due process requires defendant may inform jury of parole ineligibility when future dangerousness is at issue and LWOP is sole alternative)
- Ramdass v. Angelone, 530 U.S. 156 (2000) (plurality) (emphasizes dispositive fact is parole ineligibility under state law at time of trial)
- Shafer v. South Carolina, 532 U.S. 36 (2001) (reaffirming Simmons rule that defendant may inform jury of parole ineligibility to rebut future-dangerousness arguments)
- Kelly v. South Carolina, 534 U.S. 246 (2002) (applies Simmons principles in capital sentencing context)