Case 1: 581 US _ (2017): Bobby James Moore versus Texas
Summary of the Case
The instant Supreme Court case is specifically limited to the capital sentencing of Bobby James Moore. Moore had been convicted in a charge Capital Murder in 1980 and sentenced to death (Skelton, 2017). The nature of trial and conviction for murder was not the subject of the Appeal to the Court of Criminal Appeals of Texas nor the Supreme Court case. In 2001, Moore made an application for Habeas Corpus to the lower court based on the Supreme Court decision in Atkins v. Virginia . The primary basis for the Habeas Court application was that due to a psychological impediment, Moore had a diminished capacity and should not have been sentenced to death. The Habeas court concurred with Moore and offered the relief sought hence an appeal by the State of Texas to the Court of Criminal Appeals of Texas with the intent to challenge the decision of the Habeas Court (Skelton, 2017). The appeal was successful as the Court of Criminal Appeals of Texas concurred with the Appellants that Moore’s psychological state should be assessed based on the understanding of psychology as at the time of conviction. Aggrieved by the decision, Moore petitioned the Supreme Court.
The Legal Question before the Supreme Court
The legal question before the Supreme Court related to a combined consideration of Eighth Amendment’s prohibition against cruel and unusual punishment alongside Atkins v. Virginia . The Court was meant to evaluate if the psychological and intellectual capacity of a convict for the purposes of capital sentencing should be based on the psychological understanding as at the time of conviction or the most recent understanding of the subject (Skelton, 2017).
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The Holding
The Supreme Court arrived at a decision for the Petitioner vide a 5-3 majority with the majority decision being delivered by Justice Ruth Bader Ginsburg. In the ruling, the majority not only set a standard for evaluation of intellectual capacity but also castigated the Appeals Court for the way the appeal was handled. Justice Ginsburg argued that when considering the intellectual capacity of a convict for the purposes of sentencing, advancements in the field of psychology and psychiatry cannot be ignored and must be factored in. Further, Justice Ginsburg also argued that the Appeals Court had applied common stereotypes as evidential factors during the determination of the Appeal (Skelton, 2017). The Supreme Court, therefore, reversed the decision of the Court of Criminal Appeals of Texas and found in favor of the Petitioner, Moore. The minority opinion, led by Chief Justice John G. Roberts, Jr. differed with the majority and concurred with the Appeals Court (Skelton II, 2017). According to Chief Justice Roberts, the Appeals court may have erred in factoring stereotyping in its determination but that does not render its eventual determination wrong. The error in procedure did not result in an error in conclusion. According to the minority, determining that Moore was not intellectually challenged enough to be exempted from the death sentence was still the right decision, in spite of the erroneous process undertaken by the Appeals court.
Personal Reflection on the Opinion
After a careful evaluation of the court case and the majority and minority decisions of the Supreme Court, I agree with the majority decision that the relief sought by the petitioner should have been granted. For a start, the instant case involves a capital offense which is both an extreme and irreversible form of punishment that cannot be made up for through a pecuniary relief. When such a punishment is being considered, every benefit of the doubt should be accorded to the convict. Secondly, psychology is not an absolute science hence it keeps on evolving. For example, the American Psychology Association considered homosexuality as mental ailment up to the 1970s (Burton, 2015). Advancements in psychology must be factored in cases including those that had happened before the advancements were made. Based on these two important factors, the majority decision as presented was the right decision.
Case II: 580 US _ (2016): Shaun Michael Bosse versus Oklahoma
Summary of the Case
The Supreme Court case herein related to the procedure through which the petitioner, Shaun Michael Bosse was sentenced to death. Bosse had been convicted for the first-degree murder of three people, two of them minors. The trial and conviction of Bosse were not canvassed either in the appeal or subsequent Supreme Court case. However, as per the local criminal procedure in Oklahoma, a jury hearing was held to determine whether or not Bosse should be given a capital sentence (Cornel Law School, 2018). It is this special hearing that informed the course of action in the appeal and subsequent Supreme Court Petition. During the hearing, relatives of Bosse’s victims were called to render their opinion to the jury about the sentencing. As per the record, Bosse objected to the calling of these relatives but was overruled by the trial court. The jury then proceeded to sentence Bosse to death as per the recommendations of the family members called. Bosse then appealed to the Oklahoma Court of Criminal Appeals against the death sentence claiming that calling relatives to give their opinion in a capital sentence jury hearing was outlawed as per Booth v. Maryland’s interpretation of the Eighth Amendment (Cornel Law School, 2018). Bosse’s appeal was rejected on the basis that Booth v. Maryland’s application in the case had been overruled by Payne v. Tennessee decision which happened four years after the Booth v. Maryland ruling. Aggrieved by the decision, Bosse petitioned the Supreme Court of the United States.
The Legal Question before the Supreme Court
The Supreme Court was called upon to determine the complicated issue of whether the later ruling in Payne v. Tennessee overruled the ruling in Booth v. Maryland as both have a seemingly different opinion about whether or not the Eighth Amendment prohibits the calling of relatives of the victim to provide an opinion with regard to whether or not a convict should be sentenced to death (Oyez).
The decision of the Court
By a Per Curiam decision drawn by Justice Thomas, the Supreme Court found in favor of the petitioner Bosse and against the respondent while also overruling the Oklahoma Court of Criminal Appeals (Cornel Law School, 2018). In its determination, the Supreme Court to some extent concurred with the Oklahoma Court of Criminal Appeals that the Supreme Court has the ability to overrule itself in a subsequent ruling. However, in the case of Payne v. Tennessee , the Supreme Court did expressly indicate that the said ruling should not be considered as having overruled the decision in Booth v. Maryland. By indicating that Payne v. Tennessee overruled the position in Booth v. Maryland the said appeals court was in itself overruling a ruling of the Supreme Court which is ultra vires of the Oklahoma Court of Criminal Appeals (Cornel Law School, 2018). The Supreme Court, therefore, reversed the ruling of the appeals court and sent the matter back for further determination on the sentencing of the convict by the lower court.
Reflection on the Case
In the instant case, a death sentence has been meted on a convict who has been found guilty of an aggravated offense . Based on a careful analysis of the facts of the case, it can be said that a capital sentence fits the crime that Bosse is said to have committed. It is also possible that the jury might have arrived at a capital sentence even without the opinion of the family members, more so because Bosse was convicted of killing a mother and two children. However, in criminal cases in general, and more particularly in capital offense cases, the due procedure cannot be compromised under any circumstances. In the instant case, the trial court compromised due procedure by calling relatives of the victims against objections of the convict. The violation of law condemned the entire process hence convoluting the death sentence. The Supreme Court was right to vacate the death sentence.
References
Oyez. (n.d). Bosse v. Oklahoma. Retrieved May 31, 2018, from https://www.oyez.org/cases/2016/15-9173
Burton, N. (2015). When homosexuality stopped being a mental disorder. Retrieved from https://www.psychologytoday.com/intl/blog/hide-and-seek/201509/when-homosexuality-stopped-being-mental-disorder
Cornel Law School. (2018). Bosse v. Oklahoma. Retrieved from https://www.law.cornell.edu/supremecourt/text/15-9173
Skelton II, C. (2017). Moore v. Texas, 581 U.S. ___ (2017). Retrieved from https://supreme.justia.com/cases/federal/us/581/15-797/dissent4.html
Skelton, C. (2017). Moore v. Texas, 581 U.S. ___ (2017). Retrieved from https://supreme.justia.com/cases/federal/us/581/15-797/opinion3.html
