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Tuilaepa v. California
United States Supreme Court
512 U.S. 967, 114 S. Ct. 2630, 129 L. Ed. 2d 750 (1994)
Tuilaepa (defendant) committed the murder and rape of Bonnie Stendal during the course of a burglary. The California penal code provided that two phases, a guilt phase and a penalty phase, must occur for a defendant charged with first-degree murder. The guilt phase determined whether the defendant was eligible for the death penalty. The eligibility determination was to be made based on the finding of one or more of 19 special circumstances listed in the first-degree-murder statute. The penalty phase determined the selection of the sentence for the defendant. The selection determination was to be made based on an individualized consideration of all relevant mitigating circumstances. Tuilaepa challenged the California first-degree-murder scheme for unconstitutional vagueness. Specifically, Tuilaepa challenged three of the factors that the sentencer was required to consider: the circumstances of the crime, the defendant’s prior criminal activity, and the defendant’s age. The California Supreme Court found the factors to be constitutional. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Kennedy, J.)
Dissent (Blackmun, J.)
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