New York State Death Penalty Laws
New York had the death penalty for violent crimes until 2004, when the New York Court of Appeals ruled that the death penalty was unconstitutional in the People of New York v. Steven LaValle (3 N.Y.3d 88). When the case was decided, all prisoners on death row had their sentences commuted to life in prison, and the death penalty is no longer offered during sentencing. Subsequent attempts to reinstitute the death penalty have met with little support and have not succeeded.
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People v. LaValle
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Stephen LaValle raped high-school track coach Cynthia Quinn before stabbing her over 70 times with a screwdriver on the morning of May 31, 1997. After an investigation, LaValle confessed to the crime, was convicted of first degree murder and rape and was sentenced to death. LaValle appealed, and defended himself in front of the New York Court of Appeals, New York's highest court. He argued that the nature of New York's "Deadlock Instructions" violated Article 1, Section 6 of the state constitution, relating to fair prosecution of capital crimes.
New York's Deadlock Instructions
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The New York Appeals Court found that Section 400.27(10) of the New York Criminal Procedure Law was unconstitutional, making all previous and subsequent assignments of the death penalty unconstitutional. Section 400.27(10) of the New York Criminal Procedure Law, colloquially called "Deadlock Instructions," refers to the information that a jury is given during sentencing. Juries were instructed that for cases of first degree murder, they had two choices for sentencing--the death penalty or imprisonment for life with no chance of parole. If the jury could not unanimously choose one of these options--i.e., if the jury became deadlocked--then the judge would be forced to sentence the prisoner to 20 to 25 years with parole. Because this third option was significantly less severe than the other two choices, LaValle argued, jury members were pressured to come to a consensus, even if some did not agree with the death penalty.
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Implications
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New York's Deadlock Instructions were unique, so the case does not have immediate implications for the death penalty for other states. However, the case does bring into question the idea of coercion of juries. It may be possible for other cases against the death penalty to show similar coercion of juries, where jury members feel forced to assign the death penalty rather than a significantly lesser punishment.
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References
- New York Courts: People of New York v. Steven LaValle
- Death Penalty Information Center: New York's Death Penalty Law Declared Unconstitutional--People v. Stephen LaValle
- New York State Legislature: 400.27 Procedure for determining sentence upon conviction for the offense of murder in the first degree
- New York State Constitution
- Photo Credit new york image by Gerhard Führing from Fotolia.com
