State v. Young – California

Nature of the Case

This was an appeal from a death sentence.

Facts

Young (D) suggested to Presnell and Jackson that they go to Cooke’s house to rob and kill him. Jackson and Presnell thought that Young was just joking but on the way to Cooke’s house Young discussed plans for their attack. Cooke let the trio in and they told him that they wanted to buy liquor. When Cooke returned with a bottle, Young pulled a knife and stabbed Cooke. Young then told Presnell to finish him and Presnell then stabbed Cooke in the back five or six times. Young divided Cooke’s money and other valuables including a coin collection between them.

Young was charged with first degree murder, first degree burglary, and robbery with a dangerous weapon. Young offered no evidence at trial and was found guilty on all counts. During the sentencing phase the jury was asked to determine three aggravating circumstances; was the murder committed while Young was engaged in a robbery, was the murder committed for pecuniary gain, and whether the murder was especially heinous, atrocious or cruel. The trial court also submitted to the jury mitigating circumstances including that Young was only 19 years old at the time of the crime. Young was sentenced to death and appealed.

Issue

In determining whether a death sentence is disproportionate to the crime, must the reviewing court look to a pool of similar cases affirmed by the reviewing court?

Holding and Rule of Law

Yes. In determining whether a death sentence is disproportionate to the crime, the reviewing court must look to a pool of similar cases affirmed by the reviewing court.

The facts presented by this appeal more closely resemble those cases in which the jury recommended life imprisonment than those in which the defendant was sentenced to death. We agree with Young that this case is similar to the Jackson case in which this court overturned a death sentence as disproportionate to the penalty imposed in similar cases. In that case the jury found that the crime was committed for pecuniary gain and the sole mitigating circumstance was that Jackson had no prior criminal activity. In this case the death sentence was disproportionate.

Disposition

Affirmed in part and reversed in part.