Weeks v. Angelone

Lonnie Weeks, Jr., (defendant) shot and killed a Virginia state trooper. A jury found Weeks guilty of capital murder. The trial proceeded to the penalty phase. The state sought to prove two aggravating circumstances: that Weeks posed a threat of future dangerousness and that his offense was outrageously vile or inhuman. During the jury’s deliberations regarding which punishment to impose, the jury asked whether Weeks would have the possibility of parole if given a sentence of life imprisonment. The judge gave a vague answer that did not answer the jury’s question directly. Defense counsel objected to the judge’s response. Later that day, the jury asked another question seeking clarification of their duty. The jury asked whether it was required to impose a death sentence if it found at least one of the aggravating factors to be proved. The judge merely referred the jury to a specific paragraph of the jury instructions. Defense counsel disagreed with the judge’s response again and asked for an instruction clarifying that the jury may impose a life sentence even if they found one of the factors to be proved beyond a reasonable doubt. The jury deliberated for two more hours before returning a verdict sentencing Weeks to death. Weeks sought habeas corpus relief, which was denied. The United States Supreme Court granted certiorari.