Welcome to the MedLibrary.org Wikipedia Supplement on People v. LaValle -- Please Click to Return to Front Page

People v. LaValle
New York Court of Appeals
Decided June 24, 2004
Full case name: The People of New York v. Steven LaValle Citations: 3 N.Y.3d 88 Prior history: Defendant convicted; judgment affirmed; sentence later invalidated and remanded, CPL 470.305c
Holding
The current statute of capital punishment in the state of New York was declared unconstitutional as it violated article one, section six of the state constitution.
Court membership
Chief Judge Judith S. Kaye
Associate Judges George Bundy Smith, Albert Rosenblatt, Carmen Ciparick, Robert S. Smith, Victoria Graffeo, Susan P. Read
Case opinions
Majority by: G. Smith Joined by: Kaye, Ciparick Concurrence by: Rosenblatt Dissent by: R. Smith Joined by: Graffeo, Read
Laws applied
New York State Constitution article one, section six

People v. LaValle, 3 N.Y.3d 88, was a landmark decision by the New York Court of Appeals, the highest court in New York State, in which the court ruled that the state's death penalty statute was unconstitutional because of the statute's direction on how the jury was to be instructed in case of deadlock. The case was decided on June 24th, 2004.

Facts

Stephen LaValle, who murdered high-school track coach Cynthia Quinn during her morning jog (the court states she was stabbed seventy-three times with a screwdriver) and then raped her, was convicted by a lower court of murder in the first degree and of rape. The Supreme Court of Suffolk County sentenced him to death. LaValle largely argued the case himself (despite a complete lack of legal training), after a falling out between him and his two attorneys. Each wanted to take the case in a separate direction. The case was eventually appealed to the highest court in New York State.

LaValle argued that his death sentence had been improperly imposed on two grounds. First, he alleged that one of the jurors (juror 16) had been biased against him from the beginning, and that during voir dire the juror had expressed an inclination towards assigning the death penalty to rapists and murderers. LaValle also argued that the emotional testimony of Quinn's husband was largely irrelevant to the case, and served only to earn him a harsher sentence from the jury.

While the court upheld LaValle's conviction, citing "overwhelming evidence of guilt" to support it (largely based on LaValle's own confession as well as eyewitness testimony), the court did invalidate the death sentence, on the grounds that it violated article one, section six of the New York Constitution.

The Court held that Section 400.27(10) [1] of the New York Criminal Procedure Law was unconstitutional. That section addressed what would happen if jury deadlocked, that is could not agree, on the penalty to be imposed, life without the possibility of parole or death. In that circumstance the trial judge would be empowered to sentence the defendant to as little as 20 years to life or as much as life without parole. Moreover, the statute required the judge to instruct the jury as to what would occur if they deadlocked.

The Court found that such an instruction could have a coercive effect on jurors who believed life without parole was the appropriate sentence, but feared that if they stuck to their vote and a deadlock resulted the defendant could get be eligible for parole in as little as twenty years. This potential for coercion violated the Due Process Clause of the New York State Constitution. The court further held that some instruction as to the consequence of deadlock was required by the due process clause of the New York State Constitution, but that it was for the legislature, not the court to provide a new instruction.

Effects

The court remanded the case to the Supreme Court of Suffolk County with instructions that a new sentence be imposed: either 20 or 25 years to life, or life imprisonment without eligibility for parole. The death sentences of New York's other two death-row inmates were also invalidated.

As of April, 2007, there have been talks by state officials of the Republican Party, notably State Senate Majority Leader Joseph Bruno, to reinstate a state death penalty that permits its usage for "cop-killers." Former governor Eliot Spitzer expressed agreement with the intention of the legislation, but did not actually express support for passing it. Current governor David Paterson has not taken a position.

In October 2007 The New York Court of Appeals decided People v. John Taylor ¹ which involved the last inmate on New York's Death Row. In that case the District Attorney of Queens County sought to carve an exception to Lavalle, but the court rejected that effort.

References

Further reading

• Fahey, Joseph E. (2006). "Death Penalty Jurisprudence in New York and the Supremacy Clause of the United States Constitution: How Supreme Is It?". Pace Law Review 27: 391. ISSN 02722410. 

External links

• Official NYS Court of Appeals Decision in People v. LaValle
• Deathpenaltyinfo.org: New York State Death Penalty Statute Declared Unconstitutional
• State Constitution of New York
• The Poughkeepsie Journal: GOP Wants Spitzer to push Death Penalty

Wikipedia content modification information:

• This page was last modified on 12 December 2008, at 06:28.

Wikipedia Authorship and Review

Wikipedia content provided here is not reviewed directly by MedLibrary.org. Wikipedia content is authored by an open community of volunteers and is not produced by or in any way affiliated with MedLibrary.org.

Wikipedia Usage Guidelines

This article is licensed under the GNU Free Documentation License. It uses material from the Wikipedia article on "People v. LaValle".

The URL for this specific entry is:

• http://medlibrary.org/medwiki/People_v._LaValle

All Wikipedia text is available under the terms of the GNU Free Documentation License. (See Copyrights for details). Wikipedia® is a registered trademark of the Wikimedia Foundation, Inc.