People v. LaValle
| People v. LaValle | |
|---|---|
 |
|
| Court | New York Court of Appeals |
| Full case name | The People of New York v. Steven LaValle |
| Decided | June 24 2004 |
| Citation(s) | 3 N.Y.3d 88 |
| Case history | |
| Prior action(s) | Defendant convicted, N.Y. Sup. Ct. Suffolk Co.; judgment affirmed, N.Y. Supt. Ct. App. Div. |
| Holding | |
| The current statute of capital punishment in the state of New York was unconstitutional as it violated article one, section six of the state constitution. | |
| Court membership | |
| Chief Judge | Judith Kaye |
| Associate Judges | Robert S. Smith, G.B Smith, Carmen Beauchamp Ciparick, Albert Rosenblatt, Victoria A. Graffeo, Susan P. Read |
| Case opinions | |
| Majority | G. Smith, joined by Kaye, Ciparick |
| Concurrence | Rosenblatt |
| Dissent | R. Smith, joined by Graffeo, Read |
| Laws applied | |
| N.Y. Const. art. I, § 6; N.Y. C.P.L. § 400.27(10) | |
People v. LaValle, 3 N.Y.3d 88 (2004), was a landmark decision by the New York Court of Appeals, the highest court in the U.S. state of New York, in which the court ruled that the state's death penalty statute was unconstitutional because of the statute's direction on how the jury was to be instructed in case of deadlock. New York has since been without the death penalty, as the law has not been amended.
Stephen LaValle, who raped, sexually molested, and murdered high-school track coach Cynthia Quinn (stabbed seventy-three times with a screwdriver) during her Sunday morning jog was tried and convicted by a lower court of rape and murder in the first degree. The Supreme Court of Suffolk County sentenced him to death. LaValle largely argued the case himself (despite a complete lack of legal training), after a falling out between him and his two attorneys; they wanted to take the case in separate directions. The case was eventually appealed to the highest court in New York State.
LaValle argued that his death sentence had been improperly imposed on two grounds. First, he alleged that one of the jurors (juror 16) had been biased against him from the beginning, and that during voir dire the juror had expressed an inclination towards assigning the death penalty to rapists and murderers. LaValle also argued that the emotional testimony of Quinn's husband was largely irrelevant to the case, and served only to earn him a harsher sentence from the jury.
While the court upheld LaValle's conviction, citing "overwhelming evidence of guilt" to support it (largely based on LaValle's own confession as well as eyewitness testimony), the court did invalidate the death sentence, on the grounds that it violated Article 1, Section 6 of the New York Constitution.
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