Tennard v. Dretke

Tennard v. Dretke, 542 U.S. 274 (2004), was a United States Supreme Court case in which the court was asked whether evidence of the defendant's low IQ in a death penalty trial had been adequately presented to the jury for full consideration in the penalty phase of his trial.[1] The Supreme Court held that not considering a defendant's low IQ would breach his Eighth Amendment rights and constitute a cruel and unusual punishment.[1]

Tennard v. Dretke
Supreme Court of the United States
Argued March 22, 2004
Decided June 24, 2004
Full case nameRobert James Tennard v. Doug Dretke, Director, Texas Department of Criminal Justice, Correctional Institutions Division
Citations542 U.S. 274 (more)
124 S. Ct. 2562; 159 L. Ed. 2d 384; 2004 U.S. LEXIS 4575; 72 U.S.L.W. 4540; 17 Fla. L. Weekly Fed. S 420
Case history
PriorTexas trial court sentenced Tennard to death; decision affirmed on appeal; decision affirmed again by the Texas Court of Criminal Appeals; habeas corpus petition denied, Civ. Action No. H-98-4238 (S.D. Tex. July 25, 2000), App. 121; Fifth Circuit affirmed, Tennard v. Cockrell, 284 F.3d 591 (2002); U.S. Supreme Court remanded for reconsideration, 537 U.S. 802 (2002); Fifth Circuit reinstated, 317 F.3d 476 (2003), cert. granted, 540 U.S. 945 (2003).
Holding
A certificate of appealability should issue where "reasonable jurists would find the district court's assessment of the constitutional claims debatable or wrong."
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityO'Connor, joined by Stevens, Kennedy, Souter, Ginsburg, Breyer
DissentRehnquist
DissentScalia
DissentThomas
Laws applied
U.S. Const. amend. VIII

Facts of the case

Robert Tennard was convicted of capital murder by a Texas jury. Tennard and two accomplices robbed and killed two neighbors. The evidence presented at trial indicated that Tennard killed one of the victims by stabbing while his accomplice used a hatchet to kill the other victim.[2] In the evidence phase of the trial, the defense presented evidence that Tennard's IQ was 67, a fact which the prosecution did not dispute. The prosecutors argued that Tennard's IQ was irrelevant to the case. The jury was instructed to evaluate two issues: did the defendant deliberately commit the crime, and was the defendant likely to be dangerous in the future?[1] The jury answered yes to both questions and sentenced Tennard to death.[1]

The defense then argued that the jury instructions in the penalty phase were inadequate, and Tennard's death penalty was in violation of the cruel and unusual punishment clause of the Eighth Amendment.[2]

Questions at issue

The District Court for the Southern District of Texas denied Tennard a certificate to appeal on the basis that a low IQ is not a sufficient reason for appeal there was no evidence presented that Tennard's behavior was mentally retarded and that mental retardation was related to the criminal act. The Fifth Circuit Court of Appeals upheld this finding.[1] The Supreme Court granted Tennard's writ of certiorari.[1]

Issue

The U.S. Supreme Court then vacated the decision and remanded it back to the Fifth Circuit for reconsideration in light of the court's contemporaneous decision in Atkins v. Virginia. The Fifth Circuit considered and rejected the Atkins claim. Tennard appealed again.

The main issue the U.S Supreme Court considered was whether the Fifth Circuit improperly denied Mr. Tennard's certificate of appeal since he had presented substantial evidence of a violation of his constitutional rights, or had "demonstrated that reasonable jurists would find the district court's assessment of the constitutional claims debatable or wrong?" (quotation in original).[2]

Outcome

The Supreme Court held that all relevant mitigating factors must be considered in the penalty phase of a death penalty case. It is not sufficient to allow the defendant to present mitigating factors during the trial if those factors are not considered in the sentencing. If the jury is not instructed to consider all relevant mitigating factors, the defendant's Eighth Amendment rights are violated as failure to do so constitutes cruel and unusual punishment.[2] The court concluded that Tennard's IQ was a relevant mitigating factor, and that the sentencing jury should have been made to consider it for the purposes of mitigation.[1]

Ultimately, Tennard's death sentence was reduced to life in prison.[3]

Significance

The case formed part of a series of decisions in which the Supreme Court adjusted and refined the capital sentencing methods of the various states.[2]

See also

Footnotes
  1. Tennard v. Dretke, 542 U.S. 274 (2004).
  2. Spain, Sarah; Schmedlen, George W. (2005). "Sentencer Could Reasonably Find That Such Evidence Warrants a Sentence Less Than Death". Journal of the American Academy of Psychiatry and the Law Online. JAAPL.org. 33 (2): 265–267. Retrieved October 24, 2007.
  3. http://www.tdcj.state.tx.us/death_row/dr_offenders_no_longer_on_dr.html
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