Valle v. Florida
132 S. Ct. 1
SCOTUS2011Background
- 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)
