Jill L. Brown, Warden v. Ronald L. Sanders (546 U.S. 212)
U.S. Supreme Court · decided January 11, 2006 · Supreme Court Database (Spaeth)
- Citation
- 546 U.S. 212 · 126 S. Ct. 884
- Decided
- January 11, 2006
- Term
- October Term 2005
- Vote
- 5–4
- Majority author
- Justice Scalia
- Issue area
- Criminal Procedure
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice Scalia delivered the opinion of the Court. We consider the circumstances in which an invalidated sentencing factor will render a death sentence unconstitutional by reason of its adding an improper element to the aggravation scale in the jury’s weighing process. I Respondent Ronald Sanders and a companion invaded the home of Dale Boender, where they bound and blindfolded him and his girlfriend, Janice Allen. Both of the victims were then struck on the head with a heavy, blunt object; Allen died from the blow. Sanders was convicted of first-degree murder, of attempt to murder Boender, and of robbery, burglary, and attempted robbery. Sanders’ jury found four “special circumstances” under California law, each of which independently rendered him eligible for the death penalty. See Cal. Penal Code Ann. § 190.2 (West Supp. 1995). The trial then moved to a penalty phase, at which the jury was instructed to consider a list of sentencing factors relating to Sanders’ background and the nature of the crime, one of .which was “[t]he circumstances of the crime of which the defendant was convicted in the present proceeding and the existence of any special circumstances found to be true.” § 190.3(a) (West 1999). The jury sentenced Sanders to death. On direct appeal, the California Supreme Court declared invalid two of the four special circumstances found by the jury. It nonetheless…
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