Amadeo v. Zant

486 U. S. 214

May 31, 1988

A memorandum was found buried in the files of Putnam County, Georgia. It proved that the county had intentionally underrepresented blacks and women in the jury pool. Tony Amadeo, who had been sentenced to death by a Putnam County jury, was well into the process of appealing the death sentence when this memo came to light. When Amadeo tried to overturn his sentence based on the memo, Georgia contended that it was too late in the appeals process to raise this new claim.

Federal judicial precedent states that new claims can be raised very late in the game if the convicted person had no real means of discovering the alleged violation at the proper time. A federal District Court ruled that Amadeo could not possibly have discovered the truth contained in the hidden memo at the time of his trial. A federal Appeals Court reversed, asserting that Amadeo’s lawyer made a tactical, and intentional decision not to challenge the jury composition at the time of trial.

Unanimously, the Supreme Court overturned the Appeals Court. Marshall began by pointing out that the factual findings of district courts can only be set aside if the appeals court finds them to be “clearly erroneous.” Marshall carefully reviewed the facts, and concluded that it would be ridiculous to call the District Court’s findings clearly erroneous. While the facts had some room for interpretation, the District Judge made a perfectly reasonable and defensible finding.

On the narrow legal issue that the Supreme Court addressed, it was correct. But the underlying case makes me sick. Yet again, here’s a depraved murderer trying to get out of his death sentence because of some BS procedural defect. What makes this case especially galling is that the manipulated jury pool was actually favorable to Tony Amadeo. To quote Marshall’s opnion, Amadeo was “a white man with a history of assaulting black people,” and he was thus thrilled that the jury pool had blacks significantly underrepresented.

I don’t care if Putnam County discriminated against blacks and women in the jury pool. Only this ought to matter: did Amadeo actually commit the murder, and did he deserve to die as punishment? In its hellbent determination to elevate irrelevant procedural minutia above those central questions, the American legal system displays a profound sickness and perversion. Sin is sin. Murder is murder. And society is badly scarred when we care less about sin and murder than procedural trivialities.

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