Lowenfield v. Phelps

Lowenfield v. Phelps, 484 U.S. 231 (1988), is a United States Supreme Court case. The Court held that the two jury polls and the supplemental charge did not unlawfully pressure the jury to give a death sentence. The Court also stated that the death sentence does not violate the Eighth Amendment. This is simply because the single statutory "aggravating circumstance" found by the jury duplicates an element of the underlying offense of first-degree murder.

Lowenfield v. Phelps
Supreme Court of the United States
Argued October 14, 1987 Decided January 13, 1988
Full case name	Lowenfield v. Phelps, Secretary, Louisiana Department of Corrections, et al.
Citations	484 U.S. 231 (more) 108 S. Ct. 546; 98 L. Ed. 2d 568; 1988 U.S. LEXIS 313; 56 U.S.L.W. 4071
Case history
Prior	Habeas corpus petition denied, 671 F. Supp. 423 (E.D. La. 1987); affirmed, 817 F.2d 285 (5th Cir. 1987); stay of execution granted, 482 U.S. 932 (1987); cert. granted, 483 U.S. 1005 (1987).
Subsequent	Rehearing denied, 485 U.S. 944 (1988).
Holding
The aggravating factor making the crime punishable by death may be found in the definition of the crime itself as long it is enough narrow and precise.
Court membership
Chief Justice William Rehnquist Associate Justices William J. Brennan Jr. · Byron White Thurgood Marshall · Harry Blackmun John P. Stevens · Sandra Day O'Connor Antonin Scalia
Case opinions
Majority	Rehnquist, joined by White, Blackmun, O'Connor, Scalia; Stevens (part III, except the last sentence)
Dissent	Marshall, joined by Brennan; Stevens (part I)
Kennedy took no part in the consideration or decision of the case.
Laws applied
U.S. Const. amend. VIII

Background

In 1984, Leslie Lowenfield, a Guyanese immigrant welder, was convicted of the 1982 killing of his girlfriend, a sheriff's deputy, and four members of her family, including a 4-year-old girl.

Opinion of the court

The court, in an opinion by Chief Justice Rehnquist, held that the trial judge's polling of the jury and supplemental Allen instruction did not coerce the jury to return a verdict of guilty. The Court also rejected a challenge that Louisiana's death penalty statute did not sufficiently narrow the category of defendants who are eligible for the death penalty. The aggravating circumstance in the case, intentionally killing more than one person was found by the jury in the guilt phase after returning three first-degree murder verdicts.

Subsequent developments

Lowenfield was executed by electric chair on April 13, 1988, at the age of 34.

See also

• List of United States Supreme Court cases, volume 484
• List of United States Supreme Court cases
• Lists of United States Supreme Court cases by volume
• List of United States Supreme Court cases by the Rehnquist Court

General:

• Capital punishment in Louisiana
• Capital punishment in the United States
• List of people executed in Louisiana

External links

• Text of Lowenfield v. Phelps, 484 U.S. 231 (1988) is available from: CourtListener Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)