In an opinion published earlier this week, the California Supreme Court upheld a Superior Court decision imposing the death penalty sentence on Sean Vines, reports the Sacramento Bee. Vines was sentenced back in 1997 for the murder of Ronald Joshua Lee, 21, at a McDonald's in Sacramento.
For criminal defense attorneys or those attorneys interested in evidentiary or constitutional death penalty arguments, the recently published Vines opinion is an interesting one. The issues raised by Vines' attorneys address whether the death penalty is constitutional and relate to the admission of victim impact evidence at the sentencing stage of a capital case.
The events of the case involve a shooting during the course of a robbery at a McDonald’s, where Lee, a managerial trainee at the McDonald’s, was killed by Sean Vines, who had once worked at the same McDonald’s with Lee. According to witness testimony, the victim was shot in the back of the head after he had said the defendant’s name, having recognized him.
Defense attorneys attempted to assert that the death penalty was unconstitutional and that the long delay between the sentencing at the execution constituted cruel and unusual punishment.
Defense attorneys also contested the trial court’s admission of victim impact evidence, namely a home video depicting the victim singing and rapping.
Said the court in its opinion: “The medium itself may assist in creating an emotional impact upon the jury that goes beyond what the jury might experience by viewing still photographs of the victim or listening to the victim’s bereaved parents.” However, the court noted that such evidence could be introduced, provided the court monitored the jury’s reaction and provided that the evidence contained “nothing inflammatory that would divert the jury from [its] proper function.” In this case, the evidence was found to be properly admitted.
The court unanimously rejected the arguments made by Vines’ counsel. Vines remains on death row.
- California Law Resources (FindLaw)
- Criminal Law Practice Center (FindLaw)
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