## Facts

- Monty Lee Eddings was 16 years old when he ran away from home with friends, taking three of his father’s firearms, including a sawed-off .410 shotgun.
- During a traffic stop by Oklahoma Highway Patrol officer Larry Crabtree, Eddings fired the shotgun from the vehicle window, killing Crabtree, and then fled.
- Eddings was tried as an adult and convicted of first-degree murder.
- At the penalty phase, the defense presented evidence of Eddings’s turbulent and abusive upbringing, serious emotional disturbance, and developmental immaturity.
- The State sought the death penalty based on three alleged aggravating circumstances: the murder was especially heinous, atrocious, or cruel; it was committed to avoid lawful arrest; and Eddings posed a continuing threat of future violence.
- The trial judge found all three aggravators and treated Eddings’s youth as the only mitigating factor, refusing as a matter of law to consider his upbringing and emotional disturbance as mitigation.
- The Oklahoma Court of Criminal Appeals affirmed the death sentence.

## Issues

1. Whether the Eighth and Fourteenth Amendments permit a capital sentencer to refuse, as a matter of law, to consider relevant mitigating evidence concerning a defendant’s background and emotional disturbance.
2. Whether a death sentence is valid when the sentencer considers youth but excludes other proffered mitigating circumstances from consideration.

## Decision

- The Supreme Court vacated Eddings’s death sentence and remanded for further proceedings.
- The Court held that capital sentencing requires individualized consideration of mitigating factors.
- The Court ruled that a sentencer may determine the weight of mitigating evidence but may not refuse to consider relevant mitigating evidence as a matter of law.
- The Court concluded that evidence of Eddings’s difficult family history and emotional disturbance was relevant mitigation that had to be considered.

## Legal Principles

- In capital cases, the sentencer must not be precluded from considering any relevant mitigating evidence concerning the defendant’s character, record, or the circumstances of the offense offered as a basis for a sentence less than death.
- The constitutional requirement to allow consideration of mitigation applies not only to statutory exclusions but also to a sentencer’s legal refusal to treat relevant evidence as mitigating.
- A sentencer may assign little weight to mitigating evidence, but it cannot assign no weight by excluding it from consideration as legally irrelevant.
- Youth is a significant mitigating consideration, and evidence explaining a defendant’s development and emotional condition may be relevant to assessing culpability.

## Conclusion

The Court set aside Eddings’s death sentence because the trial judge excluded relevant mitigating evidence from consideration, violating the Eighth and Fourteenth Amendments’ requirement that capital sentencing be individualized and allow consideration of all relevant mitigation.


Eddings v. Oklahoma, 455 U.S. 104 (1982)