Eddings v. Oklahoma

In Eddings v. Oklahoma, 455 U.S. 104 (1982), the Supreme Court reiterated its holding in Lockett that in order to ensure that capital punishment is "imposed fairly, and with reasonable consistency, or not at all," sentencing courts must consider any relevant mitigating factor, including "the circumstances of the offense together with the character and propensities of the offender." Addressing whether the state trial court erred in refusing to consider proposed mitigating evidence, the Supreme Court held that the trial court may not "refuse to consider, as a matter of law, any relevant mitigating evidence?. The sentencer ... may determine the weight to be given relevant mitigating evidence. But it may not give it no weight by excluding such evidence from its consideration." Id. at 114-15. In Eddings, the United States Supreme Court overturned a defendant's death sentence because the trial court refused to consider in mitigation circumstances involving the fact that the defendant was abused as a child. 455 U.S. at 113. The Supreme Court concluded that both the trial court and the appellate court refused to weigh this mitigating evidence because they "found that the evidence in mitigation was not relevant because it did not tend to provide a legal excuse from criminal responsibility." Id. Thus, the Court held that both the trial court and the appellate court erred in failing to consider this evidence in mitigation, stating "there can be no doubt that evidence of a turbulent family history, of beatings by a harsh father" is particularly relevant even though this evidence did "not suggest an absence of responsibility for the crime of murder, deliberately committed in this case." Id. at 115-16.