Mccleskey V. Kemp Racial Disparities In Death Penalty
1. McCleskey v. Kemp (1987)
Facts:
Warren McCleskey, a Black man in Georgia, was sentenced to death for murder. He challenged the sentence, citing a large statistical study (the Baldus study) showing that Black defendants who kill white victims are more likely to receive the death penalty.
Issue:
Does statistical evidence of racial bias violate the Equal Protection Clause of the 14th Amendment?
Holding:
The Supreme Court ruled no. The Court held that statistical evidence alone is insufficient without showing intentional discrimination in McCleskey’s specific case.
Significance:
This decision made it much harder to prove racial bias in death penalty cases, requiring evidence of intentional racial discrimination.
2. Batson v. Kentucky (1986)
Facts:
A Black defendant claimed the prosecution excluded Black jurors based on race.
Holding:
The Supreme Court ruled that racial discrimination in jury selection violates the Equal Protection Clause.
Significance:
Set a precedent limiting racial bias in jury selection — a key factor in fair trials, including death penalty cases.
3. Furman v. Georgia (1972)
Facts:
Challenged arbitrary and discriminatory use of the death penalty.
Holding:
The Supreme Court temporarily halted the death penalty nationwide, citing concerns about inconsistent and racially biased application.
Significance:
Brought attention to the role of racial disparities in capital sentencing and led to reforms in death penalty laws.
4. McGautha v. California (1971)
Facts:
Before Furman, challenged arbitrary jury sentencing in death penalty cases.
Holding:
Court ruled no constitutional requirement for specific standards in death penalty sentencing, which allowed discretion that sometimes led to racial disparities.
Significance:
This decision indirectly contributed to racial disparities until Furman revised the approach.
5. Johnson v. California (2005)
Facts:
Challenge to racially segregated jury selection procedures.
Holding:
The Supreme Court ruled that any racial classification in jury selection must pass strict scrutiny and not violate equal protection.
Significance:
Further tightened scrutiny on racial bias in jury procedures, helping reduce discriminatory practices.
6. Harmelin v. Michigan (1991)
Facts:
Challenged mandatory life sentence without parole for possession of large amounts of drugs.
Holding:
Though not a death penalty case, the Court upheld harsh sentencing without considering racial disparities, illustrating limits of constitutional claims based on sentencing disparities.
Significance:
Shows the Court’s reluctance to intervene on sentencing disparities without clear constitutional violation.
Summary Table
| Case | Issue | Holding Summary | Significance |
|---|---|---|---|
| McCleskey v. Kemp | Statistical racial bias in death penalty | Statistical evidence insufficient without intent | Harder to prove racial bias claims |
| Batson v. Kentucky | Racial discrimination in jury selection | Race-based exclusion of jurors unconstitutional | Limits racial bias in juries |
| Furman v. Georgia | Arbitrary death penalty application | Death penalty temporarily halted for inconsistency | Highlighted racial disparities |
| McGautha v. California | Jury discretion in sentencing | No specific standards required, enabling disparities | Allowed discretionary sentencing |
| Johnson v. California | Racial classification in juries | Strict scrutiny on racial classifications | Reduced discriminatory jury practices |
| Harmelin v. Michigan | Sentencing disparities | Upheld harsh sentences despite disparities | Limits on addressing sentencing bias |
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