Case brief summary
To win a race discrimination claim about a death sentence, a defendant must show the people in his own case acted on purpose because of race, not just point to statistics showing a pattern.
Facts
Warren McCleskey, a black man, was sentenced to death for killing a white officer in Georgia. He presented a study showing defendants who killed white victims faced the death penalty far more often than those who killed black victims.
Procedural history
Georgia courts upheld McCleskey's death sentence. After the Supreme Court denied review, he sought federal habeas review. Lower federal courts rejected his statistical claim, even assuming the study was accurate. The Supreme Court agreed to hear the case.
Issue
Does a study showing racial patterns in Georgia's death penalty system prove one person's death sentence violates equal protection or the ban on cruel and unusual punishment?
Holding
The Court held that the study, even if accurate, did not prove McCleskey's own sentence resulted from intentional racial bias or created an unconstitutional risk of arbitrary punishment.
Reasoning
The Court said that equal protection claims require proof that specific decisionmakers in the defendant's own case acted with racial bias, and general statistics about many different cases and decisionmakers cannot establish that for one particular case. The Court emphasized that discretion by juries and prosecutors is a necessary and traditionally protected part of the criminal justice system, and that accepting McCleskey's argument could call into question sentencing in many other types of cases based on many other factors. The Court concluded that such broad challenges to how punishment is applied are better addressed by legislatures, not courts.
Opinions
Majority (Powell): The statistical study does not prove that race influenced McCleskey's own sentence, and broad statistical patterns cannot override the discretion built into jury and prosecutor decisions.
Dissent (Brennan): The study shows an unacceptably high risk that race influenced capital sentencing across Georgia, which violates the Eighth Amendment's ban on arbitrary punishment.
Dissent (Blackmun): McCleskey presented enough evidence of a racial pattern, especially in prosecutors' charging decisions, to shift the burden to the state to prove the pattern was not caused by race, which the state failed to do.
Dissent (Stevens): The problem could be fixed by narrowing death-eligible cases to the most extreme crimes, where the study shows race plays little role, so the case should be sent back for further review rather than decided outright.