Walton V. Arizona - "Heinous, Cruel, or Depraved" Aggravating Factor Is Not Unconstitutionally Vague - Counterarguments For The Court's Ruling

Counterarguments For The Court's Ruling

In spite of these developments, Walton contended that the Arizona Supreme Court's definitions had still been arbitrarily applied in his case. The Court recast this argument as a challenge to the proportionality review the Arizona Supreme Court had conducted, and then dismissed it because it deemed proportionality review to be unnecessary in the face of the adequate definition of "especially heinous, cruel, and depraved" the Arizona Supreme Court had developed. Furthermore, "the Arizona Supreme Court plainly undertook its proportionality review in good faith and found that Walton's sentence was proportional to the sentence imposed in cases similar to his." When the Court approved modern capital sentencing systems in 1976, it did so in part because states had undertaken this kind of proportionality review. In Walton, however the Court abandoned any further requirement that the states ensure the death penalty is expressly reserved for the worst of the worst by explicitly comparing the facts of individual cases.

Justice Blackmun disagreed with the Court's conclusion that the judge-only sentencing and appellate definition of "heinous, cruel, or depraved" allowed it to uphold Walton's death sentence. In the Court's view, the state supreme court's definition of the words "heinous, cruel, or depraved" provided "meaningful guidance" to trial judges charged with carrying out sentencing hearings and applying the standards the Arizona Supreme Court had propounded. Justice Blackmun pointed out that "the State Supreme Court's opinions, however, will serve to narrow discretion only if that body of case law articulates a construction of the aggravating circumstance that is coherent and consistent, and that meaningfully limits the range of homicides to which the aggravating factor will apply." In Blackmun's opinion, there was no such definition to be found in Arizona law.

In 1977, the Arizona Supreme Court took its first steps toward defining the words "heinous, cruel or depraved" by turning to dictionary definitions. "Heinous" meant "hatefully or shockingly evil;" "cruel" meant "disposed to inflict pain, especially in a wanton, insensate or vindictive manner;" and "depraved" meant "marked by debasement, corruption, perversion or deterioration." In other words, the words "especially heinous, cruel, or depraved" were meant to operate to "set the crime apart from the usual or the norm." In 1983, the court expanded this definition. "Cruelty" focused on the "pain and distress visited upon the victim," while "heinous" and "depraved" "go to the mental state and attitude of the perpetrator as reflected in his words and actions." The majority in Walton reasoned that these cases, along with other decisions applying the definitions to specific crimes, provided "meaningful guidance to the sentencer" that satisfied the Eighth Amendment's requirement of standardized capital sentencing.

Canvassing the Arizona Supreme Court's prior decisions reviewing death sentences on appeal, Blackmun concluded that Arizona's definition of "heinous, cruel, or depraved" was so broad as to be meaningless. In other words, because there were "few first-degree murders which the Arizona Supreme Court would not define as especially heinous or depraved," the aggravating circumstance did not serve its constitutional role of narrowing the class of murderers who were eligible for the death penalty. Under Arizona case law, a murder was "heinous" if the murderer used more force than necessary to accomplish the killing, but "cruel" if he used less so that the victim suffers too much before dying. "I do not believe that an aggravating factor which requires only that the victim be conscious and aware of his danger for some measurable period before the killing occurs can be said to provide a 'principled way to distinguished this case, in which the death penalty was imposed, from the many cases in which it was not.'"

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