|Lowenfield v. Phelps|
|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)|
|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).|
|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.|
|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.|
|U.S. Const. amend. VIII|
Lowenfield v. Phelps, 484 U.S. 231 (1988), is a United States Supreme Court case in which the Court held that the two jury polls and the supplemental charge did not impermissibly coerce the jury to return a death sentence, and that the death sentence does not violate the Eighth Amendment simply because the single statutory "aggravating circumstance" found by the jury duplicates an element of the underlying offense of first-degree murder.
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.
- 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
- Capital punishment in Louisiana
- Capital punishment in the United States
- List of people executed in Louisiana
- "Louisiana Executes Man, 34, Convicted of Murdering Five". The New York Times. April 13, 1988.
- "Convicted Murderer Dies In Louisiana Electric Chair". Associated Press. April 13, 1988.
- 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)