People v. LaValle
Encyclopedia
People v. LaValle, 3 N.Y.3d 88
(2004), was a landmark decision
by the New York Court of Appeals
, the highest court in the U.S. state
of New York
, in which the court ruled that the state's death penalty statute was unconstitutional because of the statute's direction on how the jury
was to be instructed in case of deadlock. New York has since been without the death penalty, as the law has not been amended.
) high-school track coach Cynthia Quinn during her Sunday morning jog was convicted by a lower court of murder in the first degree and of rape
. The Supreme Court
of Suffolk County
sentenced him to death. LaValle largely argued the case himself (despite a complete lack of legal training), after a falling out between him and his two attorneys; they wanted to take the case in a separate direction. The case was eventually appealed to the highest court in New York State.
the juror had expressed an inclination towards assigning the death penalty to rapists and murderers. LaValle also argued that the emotional testimony of Quinn's husband was largely irrelevant to the case, and served only to earn him a harsher sentence from the jury
.
While the court upheld LaValle's conviction, citing "overwhelming evidence of guilt" to support it (largely based on LaValle's own confession
as well as eyewitness
testimony), the court did invalidate the death sentence, on the grounds that it violated Article 1, Section 6 of the New York Constitution.
The Court held that Section 400.27(10) http://public.leginfo.state.ny.us/LAWSSEAF.cgi?QUERYTYPE=LAWS+&QUERYDATA=$$CPL400.27$$@TXCPL0400.27+&LIST=LAW+&BROWSER=00547314+&TOKEN=34795289+&TARGET=VIEW of the New York Criminal Procedure Law was unconstitutional. That section addressed what would happen if jury deadlocked–that is could not agree–on the penalty to be imposed: life without the possibility of parole, or death. In that circumstance the trial judge would be empowered to sentence the defendant to as little as 20 years to life or as much as life without parole. Moreover, the statute required the judge to instruct the jury as to what would occur if they deadlocked.
The Court found that such an instruction could have a coercive effect on jurors who believed life without parole was the appropriate sentence, but feared that if they stuck to their vote and a deadlock resulted the defendant could be eligible for parole in as little as twenty years. This potential for coercion violated the Due Process
Clause of the New York State Constitution. The court further held that some instruction as to the consequence of deadlock was required by the due process clause of the New York State Constitution, but that it was for the legislature, not the court to provide a new instruction.
of Suffolk County
with instructions that a new sentence be imposed: either 20 or 25 years to life, or life imprisonment without eligibility for parole
. The death sentences of New York's other two death-row inmates were also invalidated.
As of April, 2007, there have been talks by state officials of the Republican Party
, notably former State Senate Majority Leader Joseph Bruno
, to reinstate a state death penalty that permits its usage for "cop-killers." Former governor Eliot Spitzer
expressed agreement with the intention of the legislation, but did not actually express support for passing it. Former governor David Paterson
has not taken a position, but according to state senator Liz Krueger
, Paterson has always been against capital punishment
.
In October 2007 The New York Court of Appeals
decided People v. John Taylor which involved the last inmate on New York's Death Row (see Wendy's Massacre
). In that case, the District Attorney of Queens County sought to carve an exception to Lavalle, but the court rejected that effort.
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...
(2004), was a landmark decision
Landmark decision
Landmark court decisions establish new precedents that establish a significant new legal principle or concept, or otherwise substantially change the interpretation of existing law...
by the New York Court of Appeals
New York Court of Appeals
The New York Court of Appeals is the highest court in the U.S. state of New York. The Court of Appeals consists of seven judges: the Chief Judge and six associate judges who are appointed by the Governor to 14-year terms...
, the highest court in the U.S. state
U.S. state
A U.S. state is any one of the 50 federated states of the United States of America that share sovereignty with the federal government. Because of this shared sovereignty, an American is a citizen both of the federal entity and of his or her state of domicile. Four states use the official title of...
of New York
New York
New York is a state in the Northeastern region of the United States. It is the nation's third most populous state. New York is bordered by New Jersey and Pennsylvania to the south, and by Connecticut, Massachusetts and Vermont to the east...
, in which the court ruled that the state's death penalty statute was unconstitutional because of the statute's direction on how the jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
was to be instructed in case of deadlock. New York has since been without the death penalty, as the law has not been amended.
Background of the case
Stephen LaValle, who raped and murdered (stabbed seventy-three times with a screwdriverScrewdriver
A screwdriver is a tool for driving screws and often rotating other machine elements with the mating drive system. The screwdriver is made up of a head or tip, which engages with a screw, a mechanism to apply torque by rotating the tip, and some way to position and support the screwdriver...
) high-school track coach Cynthia Quinn during her Sunday morning jog was convicted by a lower court of murder in the first degree and of rape
Rape
Rape is a type of sexual assault usually involving sexual intercourse, which is initiated by one or more persons against another person without that person's consent. The act may be carried out by physical force, coercion, abuse of authority or with a person who is incapable of valid consent. The...
. The Supreme Court
New York Supreme Court
The Supreme Court of the State of New York is the trial-level court of general jurisdiction in thestate court system of New York, United States. There is a supreme court in each of New York State's 62 counties, although some smaller counties share judges with neighboring counties...
of Suffolk County
Suffolk County, New York
Suffolk County is a county located in the U.S. state of New York on the eastern portion of Long Island. As of the 2010 census, the population was 1,493,350. It was named for the county of Suffolk in England, from which its earliest settlers came...
sentenced him to death. LaValle largely argued the case himself (despite a complete lack of legal training), after a falling out between him and his two attorneys; they wanted to take the case in a separate direction. The case was eventually appealed to the highest court in New York State.
Court of Appeals decision
LaValle argued that his death sentence had been improperly imposed on two grounds. First, he alleged that one of the jurors (juror 16) had been biased against him from the beginning, and that during voir direVoir dire
Voir dire is a phrase in law which comes from the Anglo-Norman language. In origin it refers to an oath to tell the truth , i.e., to say what is true, what is objectively accurate or subjectively honest, or both....
the juror had expressed an inclination towards assigning the death penalty to rapists and murderers. LaValle also argued that the emotional testimony of Quinn's husband was largely irrelevant to the case, and served only to earn him a harsher sentence from the jury
Jury
A jury is a sworn body of people convened to render an impartial verdict officially submitted to them by a court, or to set a penalty or judgment. Modern juries tend to be found in courts to ascertain the guilt, or lack thereof, in a crime. In Anglophone jurisdictions, the verdict may be guilty,...
.
While the court upheld LaValle's conviction, citing "overwhelming evidence of guilt" to support it (largely based on LaValle's own confession
Confession (legal)
In the law of criminal evidence, a confession is a statement by a suspect in crime which is adverse to that person. Some authorities, such as Black's Law Dictionary, define a confession in more narrow terms, e.g...
as well as eyewitness
Witness
A witness is someone who has firsthand knowledge about an event, or in the criminal justice systems usually a crime, through his or her senses and can help certify important considerations about the crime or event. A witness who has seen the event first hand is known as an eyewitness...
testimony), the court did invalidate the death sentence, on the grounds that it violated Article 1, Section 6 of the New York Constitution.
The Court held that Section 400.27(10) http://public.leginfo.state.ny.us/LAWSSEAF.cgi?QUERYTYPE=LAWS+&QUERYDATA=$$CPL400.27$$@TXCPL0400.27+&LIST=LAW+&BROWSER=00547314+&TOKEN=34795289+&TARGET=VIEW of the New York Criminal Procedure Law was unconstitutional. That section addressed what would happen if jury deadlocked–that is could not agree–on the penalty to be imposed: life without the possibility of parole, or death. In that circumstance the trial judge would be empowered to sentence the defendant to as little as 20 years to life or as much as life without parole. Moreover, the statute required the judge to instruct the jury as to what would occur if they deadlocked.
The Court found that such an instruction could have a coercive effect on jurors who believed life without parole was the appropriate sentence, but feared that if they stuck to their vote and a deadlock resulted the defendant could be eligible for parole in as little as twenty years. This potential for coercion violated the Due Process
Due process
Due process is the legal code that the state must venerate all of the legal rights that are owed to a person under the principle. Due process balances the power of the state law of the land and thus protects individual persons from it...
Clause of the New York State Constitution. The court further held that some instruction as to the consequence of deadlock was required by the due process clause of the New York State Constitution, but that it was for the legislature, not the court to provide a new instruction.
Effects
The court remanded the case to the Supreme CourtNew York Supreme Court
The Supreme Court of the State of New York is the trial-level court of general jurisdiction in thestate court system of New York, United States. There is a supreme court in each of New York State's 62 counties, although some smaller counties share judges with neighboring counties...
of Suffolk County
Suffolk County, New York
Suffolk County is a county located in the U.S. state of New York on the eastern portion of Long Island. As of the 2010 census, the population was 1,493,350. It was named for the county of Suffolk in England, from which its earliest settlers came...
with instructions that a new sentence be imposed: either 20 or 25 years to life, or life imprisonment without eligibility for parole
Parole
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...
. The death sentences of New York's other two death-row inmates were also invalidated.
As of April, 2007, there have been talks by state officials of the Republican Party
Republican Party (United States)
The Republican Party is one of the two major contemporary political parties in the United States, along with the Democratic Party. Founded by anti-slavery expansion activists in 1854, it is often called the GOP . The party's platform generally reflects American conservatism in the U.S...
, notably former State Senate Majority Leader Joseph Bruno
Joseph Bruno
Joseph L. Bruno is an American businessman, and Republican politician. He was the Temporary President of the New York State Senate and its majority leader. Most recently he also served as Lieutenant Governor of New York ....
, to reinstate a state death penalty that permits its usage for "cop-killers." Former governor Eliot Spitzer
Eliot Spitzer
Eliot Laurence Spitzer is an American lawyer, former Democratic Party politician, and political commentator. He was the co-host of In the Arena, a talk-show and punditry forum broadcast on CNN until CNN cancelled his show in July of 2011...
expressed agreement with the intention of the legislation, but did not actually express support for passing it. Former governor David Paterson
David Paterson
David Alexander Paterson is an American politician who served as the 55th Governor of New York, from 2008 to 2010. During his tenure he was the first governor of New York of African American heritage and also the second legally blind governor of any U.S. state after Bob C. Riley, who was Acting...
has not taken a position, but according to state senator Liz Krueger
Liz Krueger
Liz Krueger is a member of the New York State Senate, representing a district on the East Side of Manhattan.She was first elected in February 2002 during a special election. Krueger is the ranking member on the Senate Finance Committee. She was Chairwoman of NY's Democratic Senate Campaign...
, Paterson has always been against capital punishment
Capital punishment
Capital punishment, the death penalty, or execution is the sentence of death upon a person by the state as a punishment for an offence. Crimes that can result in a death penalty are known as capital crimes or capital offences. The term capital originates from the Latin capitalis, literally...
.
In October 2007 The New York Court of Appeals
New York Court of Appeals
The New York Court of Appeals is the highest court in the U.S. state of New York. The Court of Appeals consists of seven judges: the Chief Judge and six associate judges who are appointed by the Governor to 14-year terms...
decided People v. John Taylor which involved the last inmate on New York's Death Row (see Wendy's Massacre
Wendy's Massacre
The Wendy's Massacre was a shooting spree that took place in a Wendy's fast-food restaurant at 40-12 Main Street in Flushing, Queens, New York City, New York, on May 24, 2000.-Robbery and killing of employees:...
). In that case, the District Attorney of Queens County sought to carve an exception to Lavalle, but the court rejected that effort.