In the case of Oregon v. Guzek, the Supreme Court of the United States ruled that the eighth amendment to the U.S constitution does not warrant the accused in a criminal trial the right to present evidence during the verdict stage that had not been presented in the trial stage (Americabar.org). The ruling had the impact of extending the jurisprudence to individual state courts that had prior to the ruling been allowed to make an individual determination concerning the introduction of mitigating evidence during the sentencing stage (Knowmyrights.org). The ruling of the case had implications not only for the state of Oregon but also for other states because they had to realign their criminal law jurisprudence following the directions provided by the U.S Supreme Court.
Definition
The eighth amendment of the U.S constitution is part of the Bill of Rights that is enshrined in the constitution. It states that “excessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted” (Maier, 42).
Background to the Oregon v. Guzek case
Randy Guzek had been accused of the murder of Rod and Lois Houser during an attempted robbery and was subsequently sentenced to death by an Oregon court.
He appealed the decision to the Oregon Supreme Court, which maintained the conviction but vacated the sentence. The argument had been that the sentence violated his rights granted by the constitution since the jury was not presented with all the material questions in relation to the case and as such, it was not given the opportunity to analyze evidence that might have convinced it of Guzek's innocence (Americabar.org). The Oregon Supreme Court ordered a retrial.
Guzek was still sentenced to death even in the subsequent trial after which he appealed the decision for the second time to the Oregon Supreme Court. The court once more vacated the sentence but upheld the conviction, this time, bringing up the issue of victim impact evidence used by the state, which it ruled was not admissible (Knowmyrights.org). The case was, therefore, sent for retrial.
He was sentenced to death once more, but an error occurred since the presiding judge had not instructed the jury on all the available options including a life sentence without the option of being pardoned as an alternative to the death sentence. A new trial was ordered by the Oregon Supreme Court in which it also ruled that the defendant had the right to introduce evidence that negates his guilt. The state of Oregon then petitioned the Supreme Court of the United States to review the case (Justia.com).
Legal Issues raised by the Oregon v. Guzek case
The principal issue interrogated by the Supreme Court was whether a defendant had a right to recall previously stated alibi from a witness during the sentencing stage (Americabar.org). While the alibi from his grandfather was admissible in the retrial of the case, the contention was that of the mother's alibi, which had only been introduced during the sentencing phase, was not admissible.
The defendant argued that the lack of inclusion of the mother's alibi violated not just Oregon's state laws but also the eighth amendment. He argued that he was not attempting to present new evidence to illustrate residual doubt, which is not covered under the eighth amendment rather his evidence was crucial in illustrating factual circumstances within which the crime took place.
A defendant is allowed to introduce to the court factual evidence under the eighth amendment. He argued that the alibi was important in aiding the jury in the consideration of mitigating factors. Therefore, the U.S Supreme Court would have committed an error by preventing him from presenting mitigating evidence that would have prevented a death sentence, which was in violation of the eighth amendment (Justia.com).
The accused was also of the view that the issue did not fall under the jurisdiction of the U.S Supreme Court since it was covered under Oregon's state laws (Knowmyrights.org). The state replied that while the grandfather's alibi was admissible as evidence, the mother's alibi was a subject expressly touching on the eighth amendment and as such fell under the purview of the nation’s Supreme Court.
The state and the U.S Supreme Court argued that the issue at hand was residual doubt evidence (Americabar.org). The jury had already resolved this during the trial stage and for that reason it was immaterial to introduce any more evidence to that effect in the sentencing stage of the case.
While Oregon's state death penalty statutes allowed defendants to introduce mitigating evidence relevant to any circumstance of the crime being prosecuted including the mother's alibi, the state of Oregon had a diverging opinion. The state argued that the eighth amendment does not allow a defendant to challenge their legal guilt but merely allows them to offer mitigating evidence to challenge their moral culpability to commit the crime rather than their guilt.
The prosecution was of the view that it did not matter whether the mitigating evidence was meant to prove innocence or was merely supposed to show residual doubt. The fact of the matter, as stated by law, was that the matter should not dictate the court's discretion on whether to impose the death sentence or not to the defendant.
The U.S Supreme Court stated that there were only two forms of mitigating evidence allowed under the constitution. They are evidence of the defendant's criminal record and character as well as evidence touching on the circumstances of the offence (Americabar.org). Evidence of residual doubt did not, therefore, fall under the purview of constitutional law. It also argued that the fact the defendant sort to introduce mitigating evidence was an illustration of the presumption of guilt even by the defendant himself. For that reason, allowing a defendant to present evidence based on residual doubt would raise the standard of proof in criminal cases to the extent that it would be nearly impossible to prosecute any of the criminal cases.
In the end, the U.S Supreme Court held that evidence of residual doubt cannot be used by a defendant in the sentencing stage and that the inadmissibility of the evidence at that stage did not constitute a violation of the eighth amendment. Randy Lee Guzek was eventually sentenced to death by Deschutes County Court of the state of Oregon (Justia.com). The jurisprudence set by the court led many of the states to amend their laws, especially on death penalty statutes to bring them up to par with the ruling.
Other Issues Raised under the Eighth Amendment
The eighth amendment forbids the imposition of punishments that are not proportional to the gravity of crime committed (Maier, 46). The cruelty of punishment is also a factor considered during sentencing. It was especially after the Furman v. Georgia case in which the U.S Supreme Court ruled that inconsistent sentencing of defendants to death is a violation of the eighth amendment and that it constituted a cruel and unusual punishment (Americabar.org). The determination held that there must be a reasonable level of consistency in the sentencing of cases with the same levels of gravity. The court acquitted Furman. In the case of Oregon v. Guzek, it did not amount to cruel and unusual punishment.
Excessive fines are considered a violation of the eighth amendment (Maier, 54); however, determining to what extent a fine was excessive had been a bone of contention. The Supreme Court in the Waters-Pierce Oil Co, v. Texas, the Supreme Court held that excess fines are those that are highly exaggerated to the extent that they end up taking the defendants belongings without following the law (Americabar.org). While the extent of the fines to be imposed are within the discretion of the state courts, they must do so within justifiable limits.
Implications
The case set a precedent for similar cases touching on the eighth amendment. The Constitution protects the rights and freedoms of the citizens from harassment by the government, and for that reason, the citizens are given a fair hearing during trial. However, as it was evident from the case of Oregon v. Guzek, there are certain limitations regarding the extent to which a person’s right to a fair trial can be protected. The interpretation provided by the U.S Supreme Court was clear that introducing new alibi during that was not provided during the trial stage cannot be allowed at the sentencing stage.
Conclusion
The ruling of the U.S Supreme Court in the Oregon v. Guzek case set a precedent that had profound implications in the prosecution of criminal cases, especially regarding the eighth amendment. The ruling led to many states revising their criminal law procedures to align them to the jurisprudence set by the Supreme Court. The case was, therefore, a landmark ruling that will for a long time remain a significant case law.
Works Cited
Americanbar.org. "Oregon v. Guzek, 546 U.S 517 (2006) ", American Bar Association, accessed [11 Mar, 2016], http://search.americanbar.org/search?q=Oregon+v.+Guzek&client=default_frontend&pro xystylesheet=default_frontend&site=default_collection&output=xml_no_dtd&oe=UTF- 8&ie=UTF-8&ud=1
Justia.com. " Furman v. Georgia, "Justia.com, accessed [11 Mar, 2016], http://law.justia.com/lawsearch?query=Furman%20v.%20Georgia%2C%20389%20U.S. %20347
Knowmyrights. “Case laws” Knowmyrights.org, accessed [11 Mar, 2016], https://www.google.com/search?q=Knowmyrights.org&ie=utf-8&oe=utf-8
Maier, Pauline. Ratification: The People Debate the Constitution, 1787–1788. Simon and Schuste. New York, 2010
