No right to claim innocence at sentencing
on Feb 22, 2006 at 10:10 am
After an individual has been convicted of murder, that person has no constitutional right to try to head off a death sentence by trying to offer new evidence suggesting that the conviction itself was invalid, the Supreme Court ruled unanimously on Wednesday. States thus are free to put limits on the new innocence-related evidence — such as alibi evidence — that may be offered at sentencing.
The decision, in the case of Oregon v. Guzek (04-928), involved a man — Randy Lee Guzek — convicted of murder and sentenced to death. At sentencing (the third sentencing proceeding after he had won earlier appeals), Guzek sought to introduce live testimony from his mother providing additional evidence of an alibi, beyond what she had said as a witness at the trial. The Oregon Supreme Court ruled that he had a right to offer this new evidence as a mitigating factor against a death sentence. Wednesday’s ruling overturned that result, finding no such right. The opinion by Justice Stephen G. Breyer said states were free to limit evidence of innocence to that which had been offered at trial.
Breyer wrote: “We cannot agree with the Oregon Supreme Court that our previous cases have found in the Eighth Amendment a constitutional right broad enough to encompass the evidence here at issue.”
The Court issued four rulings in decided cases. New Justice Samuel A. Alito, Jr., did not take part in any of the four — all argued before he joined the Court.
The Court, in a 7-1 ruling, decided that postal patrons may sue the Postal Service for injuries suffered because of the negligent way mail was left at a home or office. The exemption the Postal Service has for lawsuits based on flaws in delivery is limited, the Court said, to destruction of mail or delivery to the wrong address. Turning aside the Postal Service’s argument that it would now face a wave of frivolous slip-and-fall lawsuits, the Court said that was a risk faced by any business that makes home deliveries. Thus, Barbara Dolan, a Glenside, Pa.., patron who was hurt by a fall after tripping over a package left on her porch, may go forward with a lawsuit. The Postal Service had claimed immunity. The case was Dolan v. U.S. Postal Service (04-848).
Wednesday’s other two rulings came in employment law cases.
In one, the Justices decided unanimously that the 1866 civil rights law guaranteeing an equal right of all races to enter into contracts does not apply when the individual seeking relief does not have a contractual relationship with the party sued. Thus, it said, an employee of a company who claimed personal harm from loss of a business opportunity — rather than harm to the company itself — may not sue. (Domino’s Pizza v. McDonald (04-593).
That case involved John McDonald, who was president of a company that was franchised to build Domino’s restaurants in Las Vegas. A negotiator for Domino’s told McDonald, who is black, that she did not like dealing with “you people.” The chain cut off the deal, and McDonald sued under Section 1981, claiming personal injuries to himself from the loss of the deal. The Ninth Circuit permitted his lawsuit, but the Supreme Court reversed, finding that McDonald himself was not a party to the contract between Domino’s and his franchise company.
In the other job case, the Court — again unanimous — ruled that the limit of workplace bias law to firms with 15 or more employees does not limit federal court jurisdiction, but only sets a limit on who may qualify for relief. That ruling came in Arbaugh v. Y&H Corp. (04-944). The decision cleared up a prolonged conflict among lower courts, over their power to decide cases when a threshold issue is whether the employer is even covered by federal law. The issue has arisen under a variety of laws — Title VII, Americans with Disabilities Act, Age Discrimination in Employment Act, Family and Medical Leave Act, and ERISA, laws that also involve definitional terms.
The ruling revived a $40,000 verdict that a waitress at a New Orleans eatery, the Moonlight Cafe, had won under Title VII. The Court said that the employer, Y&H Corp., had failed to raise the number-of-workers limit until after the verdict was in, so could not assert it, since the number was not a jurisdictional factor.
