Oregon v. Guzek
Encyclopedia
Oregon v. Guzek, 546 U.S. 517
(2006), was a decision by the Supreme Court of the United States
, which ruled that the Eighth Amendment to the United States Constitution
does not grant criminal defendants facing the death penalty the right to introduce new evidence
of their innocence
during sentencing
that was not introduced during trial. Accordingly, states could constitutionally exclude such evidence from the sentencing phase of a capital trial.
affirmed his conviction but vacated the sentence. The court ruled that the death sentence violated the Eighth Amendment because the jury was not presented with a "general mitigation question," which would ensure that it had the opportunity to give effect to any relevant mitigating evidence
outside of the statutory factors that were submitted to it. The court remanded the case back to the trial court
for a new sentencing trial.
—as an alternative to the death penalty. Guzek was once again sentenced to death. Based on this error, the Oregon Supreme Court once again vacated Guzek's sentence and remanded for a new sentencing trial.
Seeking to avoid further errors at his fourth sentencing proceeding, the court also addressed the exclusion of alibi
evidence that Guzek had sought to admit, which consisted of transcripts
of testimony
by his mother and grandfather stating he was with them at the time of the murder. The Oregon Supreme Court ruled that under state law and the Eighth Amendment, Guzek had a right to present this evidence during his death penalty sentencing, and directed the trial court to admit all alibi evidence he submitted. The State of Oregon then petitioned the Supreme Court for review.
Although the sole remaining issue for the defendant was his right to have life without parole considered if he waived any ex post facto right, on May 5, 2010 as jury selection was starting Guzek wrote a pro-se 5-page brief demanding that life without parole (LWOP) be removed from consideration and the presiding judge, Judge Jack Billings so ordered.
In May 2010, after several further delays the case of State of Oregon vs. Randy Guzek went to trial again in Deschutes County, Oregon. On June 17, 2010, after about 5 hours of deliberation, the 8-woman, 4-man jury unanimously answered all the four questions required for a sentence of death to be rendered under Oregon's capital sentencing scheme "yes," and Guzek was immediately sentenced to death again for the murders of Rod Houser and Lois Houser.
, ruling that the Eighth Amendment
's prohibition against cruel and unusual punishment
did not create a right to introduce evidence of innocence in a defendant's death penalty sentencing phase if it had not been introduced in the trial phase. States instead were permitted by the U.S. Constitution to limit such evidence to that which was already presented at trial.
Guzek had also argued that this alibi evidence could be used to impeach
the testimony of other witnesses, and the Court left it open to the Oregon Supreme Court on remand to determine whether this was permissible under Oregon law.
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(2006), was a decision by the Supreme Court of the United States
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
, which ruled that the Eighth Amendment to the United States Constitution
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
does not grant criminal defendants facing the death penalty the right to introduce new evidence
Evidence (law)
The law of evidence encompasses the rules and legal principles that govern the proof of facts in a legal proceeding. These rules determine what evidence can be considered by the trier of fact in reaching its decision and, sometimes, the weight that may be given to that evidence...
of their innocence
Innocence
Innocence is a term used to indicate a lack of guilt, with respect to any kind of crime, sin, or wrongdoing. In a legal context, innocence refers to the lack of legal guilt of an individual, with respect to a crime.-Symbolism:...
during sentencing
Sentence (law)
In law, a sentence forms the final explicit act of a judge-ruled process, and also the symbolic principal act connected to his function. The sentence can generally involve a decree of imprisonment, a fine and/or other punishments against a defendant convicted of a crime...
that was not introduced during trial. Accordingly, states could constitutionally exclude such evidence from the sentencing phase of a capital trial.
First state appeal
Randy Lee Guzek was convicted of murder and sentenced to death. On appeal, the Oregon Supreme CourtOregon Supreme Court
The Oregon Supreme Court is the highest state court in the U.S. state of Oregon. The only court that may reverse or modify a decision of the Oregon Supreme Court is the Supreme Court of the United States. The OSC holds court at the Oregon Supreme Court Building in Salem, Oregon, near the capitol...
affirmed his conviction but vacated the sentence. The court ruled that the death sentence violated the Eighth Amendment because the jury was not presented with a "general mitigation question," which would ensure that it had the opportunity to give effect to any relevant mitigating evidence
Mitigating factor
A mitigating factor, in law, is any information or evidence presented to the court regarding the defendant or the circumstances of the crime that might result in reduced charges or a lesser sentence.-Death penalty in the United States:...
outside of the statutory factors that were submitted to it. The court remanded the case back to the trial court
Trial court
A trial court or court of first instance is a court in which trials take place. Such courts are said to have original jurisdiction.- In the United States :...
for a new sentencing trial.
Second state appeal
On remand, Guzek was sentenced to death again. He appealed, and the Oregon Supreme Court again vacated the sentence, ruling that "victim impact" evidence that the State had presented during sentencing was not relevant, and so unconstitutionally secured the death sentence. The case was remanded for a third sentencing trial.Third state appeal
During the third sentencing trial, the trial judge failed to instruct the jury about a "true-life" sentencing option—life in prison without the possibility of paroleParole
Parole may have different meanings depending on the field and judiciary system. All of the meanings originated from the French parole . Following its use in late-resurrected Anglo-French chivalric practice, the term became associated with the release of prisoners based on prisoners giving their...
—as an alternative to the death penalty. Guzek was once again sentenced to death. Based on this error, the Oregon Supreme Court once again vacated Guzek's sentence and remanded for a new sentencing trial.
Seeking to avoid further errors at his fourth sentencing proceeding, the court also addressed the exclusion of alibi
Alibi
Alibi is a 1929 American crime film directed by Roland West. The screenplay was written by West and C. Gardner Sullivan, who adapted the 1927 Broadway stage play, Nightstick, written by Elaine Sterne Carrington, J.C...
evidence that Guzek had sought to admit, which consisted of transcripts
Transcript (law)
A transcript is a written record of spoken language. In court proceedings, a transcript is usually a record of all decisions of the judge, and the spoken arguments by the litigants' lawyers. A related term used in the US is docket, not a full transcript. The transcript is expected to be an exact...
of testimony
Testimony
In law and in religion, testimony is a solemn attestation as to the truth of a matter. All testimonies should be well thought out and truthful. It was the custom in Ancient Rome for the men to place their right hand on a Bible when taking an oath...
by his mother and grandfather stating he was with them at the time of the murder. The Oregon Supreme Court ruled that under state law and the Eighth Amendment, Guzek had a right to present this evidence during his death penalty sentencing, and directed the trial court to admit all alibi evidence he submitted. The State of Oregon then petitioned the Supreme Court for review.
Fourth sentencing trial
As the result of the opinion of SCOTUS the Oregon Supreme Court reviewed the case yet again in 2007 (State of Oregon vs. Randy Lee Guzek, 153 P.3d 101 (Ore. 2007) and determined that in accordance of the SCOTUS decision that live alibi testimony would not be allowed but that prior transcript alibi testimony of the defendant's mother and grandfather would be admitted.Although the sole remaining issue for the defendant was his right to have life without parole considered if he waived any ex post facto right, on May 5, 2010 as jury selection was starting Guzek wrote a pro-se 5-page brief demanding that life without parole (LWOP) be removed from consideration and the presiding judge, Judge Jack Billings so ordered.
In May 2010, after several further delays the case of State of Oregon vs. Randy Guzek went to trial again in Deschutes County, Oregon. On June 17, 2010, after about 5 hours of deliberation, the 8-woman, 4-man jury unanimously answered all the four questions required for a sentence of death to be rendered under Oregon's capital sentencing scheme "yes," and Guzek was immediately sentenced to death again for the murders of Rod Houser and Lois Houser.
The court's decision
The United States Supreme Court unanimously reversed the Oregon Supreme CourtOregon Supreme Court
The Oregon Supreme Court is the highest state court in the U.S. state of Oregon. The only court that may reverse or modify a decision of the Oregon Supreme Court is the Supreme Court of the United States. The OSC holds court at the Oregon Supreme Court Building in Salem, Oregon, near the capitol...
, ruling that the Eighth Amendment
Eighth Amendment to the United States Constitution
The Eighth Amendment to the United States Constitution is the part of the United States Bill of Rights which prohibits the federal government from imposing excessive bail, excessive fines or cruel and unusual punishments. The U.S. Supreme Court has ruled that this amendment's Cruel and Unusual...
's prohibition against cruel and unusual punishment
Cruel and unusual punishment
Cruel and unusual punishment is a phrase describing criminal punishment which is considered unacceptable due to the suffering or humiliation it inflicts on the condemned person...
did not create a right to introduce evidence of innocence in a defendant's death penalty sentencing phase if it had not been introduced in the trial phase. States instead were permitted by the U.S. Constitution to limit such evidence to that which was already presented at trial.
Guzek had also argued that this alibi evidence could be used to impeach
Witness impeachment
Witness impeachment, in the law of evidence, is the process of calling into question the credibility of an individual who is testifying in a trial...
the testimony of other witnesses, and the Court left it open to the Oregon Supreme Court on remand to determine whether this was permissible under Oregon law.
See also
- List of United States Supreme Court cases, volume 546
- List of United States Supreme Court cases
- Capital punishment in Oregon