U.S. Supreme Court
Lewis v. Jeffers, 497 U.S. 764 (1990)
Lewis v. Jeffers
Argued Feb. 21, 1990
Decided June 27, 1990
497 U.S. 764
In affirming respondent Jeffers' first-degree murder conviction and death sentence, the Arizona Supreme Court, inter alia, independently reviewed the evidence supporting the trial court's finding of the statutory aggravating circumstance that the crime was committed "in an especially heinous, cruel or depraved manner." The court noted its recent ruling that the infliction of gratuitous violence on the victim is among the factors to be considered in determining whether the murder was "especially heinous . . . and depraved," and found the presence of this factor in light of evidence that Jeffers had climbed on top of the dead victim and hit her in the face several times, causing additional wounds and bleeding. Noting further that the apparent relish with which the defendant commits the murder is another relevant factor under its decisions, the court concluded that Jeffers' relish for his crime was evidenced by testimony that, while he was beating the dead victim, he called her a "bitch" and a "dirty snitch" and stated, as each blow landed, that "[t]his one is for" someone on whom he felt she had informed. The Federal District Court denied Jeffers' habeas corpus petition. The Court of Appeals agreed with the District Court that the "especially heinous . . . or depraved" aggravating circumstance, as interpreted and narrowed by the State Supreme Court, was not void on its face, but vacated Jeffers' death sentence on the ground that the circumstance was unconstitutionally vague as applied to him.
1. The Court of Appeals erred in holding that Arizona's construction of the "especially heinous . . . or depraved" aggravating circumstance in this case contravened Godfrey v. Georgia, 446 U. S. 420, 446 U. S. 428, and Maynard v. Cartwright, 486 U. S. 356, 486 U. S. 364. There is no dispute here that the Arizona Supreme Court applied its narrowing construction to the facts of Jeffers' case. More important, the Court of Appeals noted that the circumstance, as construed by the state courts, was not unconstitutionally vague on its face. Even if it had not so held, Jeffers' claim that Arizona has not construed the circumstance in a constitutionally narrow manner is disposed of by Walton v. Arizona, ante, at 497 U. S. 652-655, which upheld, against a vagueness challenge, the precise aggravating circumstance at issue here. Moreover, a claim identical to Jeffers' assertion that the aggravating circumstance may nevertheless be vague "as applied" chanroblesvirtualawlibrary
to him was rejected in Walton, supra, at 497 U. S. 655-656, which makes clear that if a State has adopted a constitutionally narrow construction of a facially vague aggravating circumstance and has applied that construction to the facts of the particular case, the fundamental constitutional requirement of channeling and limiting the capital sentencer's discretion has been satisfied. Pp. 497 U. S. 773-780.
2. The Court of Appeals erred in conducting a de novo, case-by-case comparison of the facts of those cases with the facts of this case to decide Jeffers' as-applied challenge. That challenge reduces, in essence, to a claim that the state court simply misapplied its own aggravating circumstance to the facts of Jeffers' case. Because federal habeas corpus relief does not lie for errors of state law, federal habeas review of a state court's application of a constitutionally narrowed aggravating circumstance is limited, at most, to determining whether the state court's finding was so arbitrary or capricious as to constitute an independent due process or Eighth Amendment violation. In making that determination, the appropriate standard of review is the "rational factfinder" standard of Jackson v. Virginia, 443 U. S. 307, 443 U. S. 319, under which the federal court must view the evidence in the light most favorable to the prosecution to determine whether "any rational trier of fact could have found the elements of the crime beyond a reasonable doubt." Under the standard, a rational factfinder could have found that Jeffers both relished his crime and inflicted gratuitous violence, given the evidence of his conduct toward the victim's body. Pp. 497 U. S. 780-784.
832 F.2d 476, (CA9 1987), reversed and remanded.
O'CONNOR, J., delivered the opinion of the Court, in which REHNQUIST, C.J.,and WHITE, SCALIA, and KENNEDY, JJ., joined. BRENNAN, J., filed a dissenting opinion, in which MARSHALL, J., joined, ante, p. 497 U. S. 674. BLACKMUN, J., filed a dissenting opinion, in which BRENNAN, MARSHALL, and STEVENS, JJ., joined, post, p. 497 U. S. 784. chanroblesvirtualawlibrary