Monday, December 23, 2013

Lowenfield v. Phelps case brief

Lowenfield v. Phelps case brief summary
484 U.S. 231 (1988)

Petitioner inmate sought review of the judgment of the United States Court of Appeals for the Fifth Circuit that denied his request for habeas corpus after being convicted of manslaughter and first-degree murder and that sentenced him to death.

Petitioner inmate killed five people and was convicted of manslaughter and first-degree murder under La. Rev. Stat. Ann. § 14:30A(3) (1986). The jury had difficulty obtaining a verdict. The trial court gave the jury a supplemental charge and sent them back to deliberate. After the charge, the jury returned the convictions and thereafter, sentenced petitioner to death. After availing all of his state remedies, petitioner sought habeas corpus relief in federal court claiming that the jury was improperly coerced by the supplemental charge given by the state court. The lower courts denied the request for habeas corpus.


  • On review, the Court affirmed the lower courts holding that the jury was not coerced by the supplemental charge because the charge never required the jury to impermissibly reveal the nature or extent of its division on the merits of the verdict. 
  • Moreover, the Court held that the jury's finding of an aggravating circumstance that was an essential element of first-degree murder was inconsequential because the use of aggravating circumstance was simply a means of narrowing the class of persons eligible for death and a way of channeling the jury's discretion.

The Court affirmed the judgment of the lower court denying petitioner inmate's request for habeas corpus relief because the state court's supplemental charge was proper and not impermissibly coercive. In addition, there was no constitutional deficiency in the use of an aggravating circumstance to impose the death penalty because it narrowed the class of persons convicted of murder who were eligible for the death penalty.

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