Facts
- Lonnie Weeks, Jr. was convicted in Virginia of capital murder for shooting Virginia State Trooper Jose Cavazos after a traffic stop involving a stolen vehicle.
- At the penalty phase, the prosecution sought a death sentence based on statutory aggravators of future dangerousness and that the offense was vile or inhuman; the defense presented mitigation witnesses.
- The jury was instructed that if it unanimously found an aggravating factor beyond a reasonable doubt, it may impose death, but if, from all the evidence, it believed death was not justified, it shall impose life imprisonment.
- During deliberations, the jury asked whether a life sentence included parole eligibility; the judge responded without directly answering the parole question.
- The jury later asked whether, upon finding at least one aggravating circumstance, it had a duty to impose death or could choose between death and life.
- The trial judge responded by directing jurors back to the relevant paragraph of the existing instructions stating they may impose death or must impose life if death was not justified from all the evidence.
- Defense counsel requested an additional clarifying instruction expressly stating the jury could impose life even after finding an aggravator; the judge refused.
- The jury returned a death sentence, stating it found an aggravating circumstance and had considered mitigation.
Issues
- Whether the Constitution is violated when a trial judge answers a capital jury’s question about whether death is required upon finding an aggravator by referring the jury back to a paragraph of otherwise adequate instructions rather than giving a further clarifying instruction.
- Whether Weeks was entitled to federal habeas relief for ineffective assistance of counsel relating to the penalty-phase instructions and jury questions.
- Whether AEDPA, 28 U.S.C. § 2254(d), barred relief because the state courts’ decisions were not contrary to, or an unreasonable application of, clearly established Supreme Court precedent.
Decision
- The Supreme Court affirmed the denial of federal habeas relief.
- Referring the jury back to a specific paragraph of constitutionally sufficient sentencing instructions, in response to the jury’s question, did not violate the Constitution.
- Under AEDPA, the Virginia Supreme Court’s approval of the instructions and the trial court’s response was not contrary to, and did not unreasonably apply, clearly established federal law.
- The state court’s rejection of Weeks’s ineffective-assistance claims was not an unreasonable application of Strickland.
Legal Principles
- The Eighth Amendment requires that a capital sentencer not be precluded from considering relevant mitigating evidence; no specific “magic words” or particular instruction format is required if the charge adequately permits mitigation consideration.
- A jury is presumed to follow the court’s instructions; when instructions already correctly state the law, a judge may respond to a jury question by directing attention to the pertinent portion.
- On federal habeas review, AEDPA permits relief only if the state court decision is contrary to, or an unreasonable application of, clearly established Supreme Court precedent.
- Ineffective assistance claims on habeas require showing deficient performance and prejudice under Strickland, and AEDPA further limits relief to unreasonable state-court applications of that standard.
Conclusion
The Court held that, in a capital case, a judge may constitutionally address a jury’s question about whether death is mandatory after finding an aggravator by pointing the jury to a clear, existing instruction preserving discretion to impose life, and that AEDPA required deference to the state courts’ approval of that approach and their rejection of related ineffective-assistance claims.