People v. LaValle | Facts of the Case
On Sunday, May 31st 1997, Cynthia Quinn while taking her morning jog, allegedly found Stephen LaValle urinating by the side of the road and yelled at him. This action completely angered LaValle who then followed her into the woods where he raped and murdered her with a screw driver he apparently found on her during the offense. He stabbed her 73 times before leaving the scene of the crime. He was arrested two days later because the samples found on Quinn’s body matched his DNA, and an eye witness had placed him as the last person seen with Mrs. Quinn.
LaValle, despite having no legal training, defended himself in court because he had previously had a falling out with his two attorneys because they wanted to proceed with the case differently. In his argument, Lavalle stated that juror number 16 was biased and had stated that they would convict him even before the hearing began. He also urged that the emotional testimony given by Cynthia’s husband was inappropriate and only served to sway the jury into giving him a harsher sentence.
Suffolk County Court
Based on the evidence, the testimony given by the eye witness and LaValle’s own confession, the Court of Suffolk County sentenced him to the death penalty on the basis of overwhelming evidence of guilt. The Court told the jurors that if they did not deadlock on the penalty to be imposed, the judge would come up with a third more lenient choice.
This meant that if the jurors did not agree on the penalty; choices being either the death penalty or life imprisonment, the judge would sentence him to a minimum of 25 years to life or as much as life imprisonment without the possibility of parole.
Court of Appeals of the State of New York
This case was appealed and taken to the Court of Appeal; the judges continued to acknowledge that LaValle was guilty, but stated that the death sentence would be invalidated on the grounds that article 1, section 6 of the New York constitution was violated. They urged that the choices given to the jurors would naturally lead to them choosing the death penalty anonymously because it would be like giving them a choice between death and 25 years to life with parole.
They stated that jurors should not be given the consequences, or ramifications, of their decision because the aim of the courts is to ensure that in, all cases, the verdict is to be reached anonymously and without coercion. The Court continued to explain that the jurors would have naturally chosen death because they would have had the fear of the convicted criminal getting out in as few as 25 years and repeating the offenses to new victims.
The case was remanded to the case of Suffolk county with instructions that the new conviction to be imposed must be either: 25 years to life, or life imprisonment without the possibility of parole. The result of this coercive effect on jurors, two other death penalty sentences were revoked and changed. LaValle was sentenced to life imprisonment without the possibility of parole, in the year 2004.
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