Smith v. Spisak
Smith v. Spisak
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Smith v. Spisak

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Smith v. Spisak

Smith v. Spisak, 558 U.S. 139 (2010), was a United States Supreme Court decision on the applicability of the Antiterrorism and Effective Death Penalty Act of 1996. It further examined issues of previous court decisions on jury instructions and the effectiveness of counsel.

Frank Spisak was an American serial killer who was convicted of three murders and one attempted murder at Cleveland State University. In February 1982, Spisak embarked on a racist, anti-Semitic shooting spree, calling it his first "seek and destroy mission" in which he was attempting to "clean up the city". Spisak was found guilty of three counts of aggravated murder and was sentenced to death.

Spisak had an accomplice, Ronald Reddish, who aided him before the shootings. Reddish was convicted of one count of attempted murder and sentenced to 7 to 25 years in prison. He was paroled in 1990.

His claims were denied by the State of Ohio in direct appeal and to the Ohio Supreme Court stating that his claim was "not well-taken on the basis of our review of the record".

Spisak filed for habeas corpus relief in the District Court for the Northern District of Ohio. First he argued that the jury instructions at the penalty phase of trial unconstitutionally required the jury to consider in mitigation only factors that the jury unanimously found mitigating (violating Mills v. Maryland, 1988). Second he argued that he had suffered significant harm because his original counsel had given an inadequate closing argument during sentencing (violating Strickland v. Washington, 1984). The District Court subsequently denied his petition.

The petition was accepted on appeal to the Sixth Circuit which blocked the State from executing Spisak. The State of Ohio appealed to the Supreme Court. In Hudson v. Spisak (552 U.S. 945, 2007) the Court remanded the case back to the Sixth Circuit and ordered the appeals court to reconsider in light of two recent cases, Schriro v. Landrigan (2007) and Carey v. Musladin (2006). The Sixth Court of Appeals again reinstated its earlier opinion. Again the State appealed and the Supreme Court granted review.

The unanimous decision was handed down by Justice Breyer. The court asked two questions; "Did the Sixth Circuit disobey the directives of the Antiterrorism and Effective Death Penalty Act (AEDPA)" and "Did the Sixth Circuit exceed its authority when it presumed that Mr. Spisak suffered harm by deficient counsel?" It answered yes to both.

In Mills v. Maryland (1988), the Supreme Court ruled that when imposing the death penalty the jury must be allowed to consider any mitigating circumstances that included any part of the defendant's record. In addition the jury must be allowed to consider "any relevant mitigating evidence."

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