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1 1 (July 6, 2000)

handle is hein.crs/crsahkg0001 and id is 1 raw text is: Order Code RS20620
July 6, 2000

Capital Punishment: Summary of Supreme Court
Decisions During the 1999-00 Term
Paul Starett Wallace, Jr.
Specialist in American Public Law
American Law Division

Summary

1 120 S. Ct. 1479 (2000).
2 Slip Op. No. 99-7000 (U.S. June 12, 2000).
3 120 S. Ct. 727 (2000).
4 120 S. Ct. 1479 (2000).

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With the exception of the Supreme Court's ruling in Williams v. Taylor,' the Court
did not find any serious reversible error in the lower courts' opinions reviewed during the
1999-2000 term that relate to capital punishment. In Ramdass v. Angelone,2 it was
decided that a habeas corpus petitioner could not obtain relief from his death sentence
on the ground that the state courts should have taken a less technical approach to
determining whether he was entitled to have the penalty phase jury instructed that he
would be ineligible for parole if the jury recommended a sentence of life imprisonment.
The state courts reasoned that because judgment had not been entered on one of the
petitioner's convictions, he did not have three strikes for purposes of the state's parole
ineligibility law. The Supreme Court affirmed the decision on June 12, 2000, reasoning
that the entry of a judgment of conviction upon a jury's guilty verdict in another case was
not a forgone conclusion in view of the possibility of post-trial motions. In Weeks v.
Angelone,3 the Court affirmed the Fourth Circuit Court of Appeals denying the
petitioner's appeal of a death penalty sentence and federal habeas corpus petition,
deciding that the jury instructions were constitutionally adequate. In Williams v. Taylor,'
it was generally recognized that a defendant is barred from proceeding with federal
habeas corpus claims which were not developed in the state habeas corpus petition,
however, the Court allowed an evidentiary hearing on two claims due to the petitioner's
diligence in pursuing them.