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Supreme Court of the United States - 337 U.S. 241
Tags: Criminal law, Due process
tl;dr:
Consideration of a sentencing report that contains information not presented at trial does not violate a defendant's right to due process.Video Summary
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The legal case involves a defendant who was convicted of first-degree murder and sentenced to death by a New York state court judge. The judge erred by discussing additional information obtained through the court's Probation Department and other sources in open court. The defendant challenges the constitutionality of New York's policy that allows judges to consider information obtained outside the courtroom from individuals whom the defendant has not been allowed to confront or cross-examine. The case raises a question regarding the rules of evidence that apply to a judge's acquisition of information to guide them in sentencing a convicted defendant. The lower court may have erred in not considering the defendant's argument. The practice of individualizing sentences distinguishes between first-time and repeat offenders, and indeterminate sentences have largely replaced rigidly fixed punishments. Restricting information obtained through investigational techniques would undermine modern penological procedural policies that have been cautiously adopted throughout the nation.
The dissenting opinion in this case argues that the judge made an error in sentencing the defendant to death, despite the jury's unanimous recommendation for life imprisonment. The judge relied on a probation report that contained inadmissible evidence, including irrelevant allegations of prior crimes and hearsay, which violated the defendant's due process rights. The probation report cannot be admissible in trial and cannot be examined by the defendant in a capital case. Therefore, the judge's reliance on the probation report to sentence the defendant to death was not in compliance with due process, and the recommendation of the jury for life imprisonment should have been respected.
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