Maynard v. Cartwright

486 U. S. 356

June 6, 1988

A murderer named Cartwright challenged his death sentence on the ground that an aggravating circumstance which the jury used to give him the death penalty was void for vagueness. That aggravating circumstance? That the murder was “especially heinous, atrocious, or cruel.” Because there was no further elaboration, and because state courts hadn’t offered any narrowing interpretation, Cartwright charged that these words were too vague to base a death sentence on.

The Court unanimously agreed. White explained that the Court was effectively bound by a 1980 case that had held a similar standard from Georgia to be too vague for Eighth Amendment purposes. In both instances, the standards failed to give any concrete guidance to jurors, and allowed them too much unbounded discretion. White vacated the death sentence, but hinted that new developments in Oklahoma law might allow it to be easily reimposed on remand. Brennan, joined by Marshall, filed his obligatory concurrence to state that the death penalty was always unconstitutional.

Although the 1980 case did control, at least one Justice should have had the guts to call for overruling it. While “especially heinous, atrocious, or cruel” is not exactly self-defining, in some instances a murder will indisputably fit that description. And Cartwright committed such a murder. I’ll let Byron White himself lay it out for you

“On May 4, 1982, after eating their evening meal in their Muskogee County, Oklahoma, home, Hugh and Charma Riddle watched television in their living room. At some point, Mrs. Riddle left the living room and was proceeding towards the bathroom when she encountered respondent Cartwright standing in the hall holding a shotgun. She struggled for the gun and was shot twice in the legs. The man, whom she recognized as a disgruntled ex-employee, then proceeded to the living room where he shot and killed Hugh Riddle. Mrs. Riddle dragged herself down the hall to a bedroom where she tried to use a telephone. Respondent, however, entered the bedroom, slit Mrs. Riddle’s throat, stabbed her twice with a hunting knife the Riddles had given him for Christmas, and then left the house. Mrs. Riddle survived and called the police.”

I defy anyone to seriously argue that this is not “especially heinous, atrocious, or cruel.” No one can fail to see that it is. Under the guise of respecting precedent, the Supreme Court once again mutilated justice by letting a murderer go free on patently specious grounds.

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