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Valle v. Florida
132 S. Ct. 1
SCOTUS
2011
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Background

  • Valle was sentenced to death over 33 years ago and now faces execution after long death-row confinement.
  • Valle petitions for a stay and an Eighth Amendment challenge to the prolonged delay.
  • Breyer cites Lackey v. Texas and Knight v. Florida as precedents acknowledging the cruelty of lengthy delays.
  • He notes studies and prior opinions describing the psychological and barbaric conditions of death rows and the potential for insanity during long waits.
  • The average death-row wait is about 15 years; Valle’s 33-year wait is more than twice this average and among the longest delays observed.
  • Breyer questions the strong justifications for the death penalty (deterrence, incapacitation) in light of such delay and emphasizes the community's moral sensibility and risk of wrongful execution.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether decades-long delay on death row violates the Eighth Amendment Valle argues prolonged delay is cruel State argues delay may be due to procedural requirements and does not automatically violate the Amendment yes, stay granted (Eighth Amendment concern supported)

Key Cases Cited

  • Lackey v. Texas, 514 U.S. 1045 (1995) (recognizes cruel effects of long delay on death row (certiorari denial))
  • Knight v. Florida, 528 U.S. 990 (1999) (concerns about lengthy delays and death penalty administration)
  • In re Medley, 134 U.S. 160 (1890) (describes the 'horrible' feelings of uncertainty surrounding execution)
  • Solesbee v. Balkcom, 339 U.S. 9 (1950) (noting insanity during awaiting execution as a potential consequence)
  • Spaziano v. Florida, 468 U.S. 447 (1984) (discusses moral sensibility and retributive considerations)
Read the full case

Case Details

Case Name: Valle v. Florida
Court Name: Supreme Court of the United States
Date Published: Sep 28, 2011
Citation: 132 S. Ct. 1
Docket Number: 11-6029 (11A229)
Court Abbreviation: SCOTUS