Payne v. Tennessee
Facts: After spending a morning and afternoon drinking beer and injecting cocaine, Pervis Tyrone Payne entered the apartment of 28-year-old Charisse Christopher and her two children, Lacie, age two and Nicholas, age three at approximately 3:00 p.m. on June 27th, 1987. Payne made sexual advances toward Charisse Christopher. She resisted, which lead Payne to kill both Charisse and Lacie. Nicholas was found with several severe stab wounds that completely penetrated him front to back, but he managed to survive. Payne was apprehended later that day hiding in the attic of a former girlfriend’s house. Payne was convicted by a jury of two counts of murder. At sentencing, Payne presented the testimony of his mother, father, Bobbie Thomas and a clinical psychologist. These testimonies’ showed Payne was of good character, he attended church and he was of low intelligence and mentally handicapped. The State presented the testimony of Ms.
Christopher’s mother, who spoke of the negative impact of the murders on Nicholas. Furthermore, the prosecutor presented argument regarding Nicholas’ experience. The jury sentenced the Payne to death on each count of murder. History: Pervis Tyrone Payne was arrested and charged with two counts of first-degree murder, the jury sentenced Payne to death on each count of murder. Issue: Does the Eighth Amendment prohibit a capital sentencing jury from considering “victim impact” evidence relating to the personal characteristics of the victim and the emotional impact of the crimes on the victim’s family?
Finding: No. Victim impact evidence shall not be considered according to the United States Supreme Court. This rule was because victim impact evidence presents factors about which the defendant may have been unaware of and therefore, the evidence has nothing to do with the “blameworthiness” of a particular defendant.
So basically, no evidence outside the case and not relating directly to the circumstances of the crime was admitted. In the present case, however, the Supreme Court expressed the view that “a State may properly conclude that for the jury to assess meaningfully the defendant’s moral culpability and blameworthiness, it should have before it at the sentencing phase evidence of the specific harm caused by the defendant.”
So, a State may permit the admission of victim impact evidence, as the Eighth Amendment presents no per se bar. The Supreme Court of Tennessee affirmed the conviction and sentence. The court rejected Payne’s contention that the admission of the grandmother’s testimony and the State’s closing argument constituted prejudicial violations of his rights under the Eighth Amendment as applied in Booth v. Maryland, 482 U.S. 496 (1987), and South Carolina v. Gathers, 490 U.S. 805 (1989). Rational: The court stated “Stare decisis is not an inexorable command; rather, ‘it is a principle of policy and not a mechanical formula of adherence to the latest decision.’”
So basically, not all laws are set completely in stone and it can change over time from case to case. The court states that neither the law nor the facts supporting the prior cases have changed, merely the personnel of the Supreme Court have changed. My Notes: A few things I noticed was I unclear how Payne could argue that introducing such evidence as the grandmother testimony encourages jurors to decide for the death penalty based on emotions rather than reason. But, having his parents testify that he was of good character as plays on emotion, rather than reason. To me, only after introducing victim impact evidence can the juries meaningfully determine the proper punishment. After all the whole reason for this is to protect the victim right?