Arave v. Creech
United States Supreme Court
507 U.S. 463 (1993)
Relevant factsFree
Creech (defendant), already serving life sentences for prior murders, brutally killed a fellow, already-helpless inmate; the sentencing judge found the "utter disregard for human life" aggravating factor applied, and the Idaho Supreme Court had previously construed that phrase to mean "the cold-blooded, pitiless slayer," but the Ninth Circuit found even that narrowed construction unconstitutionally vague on habeas review.
IssueFree
Whether, to be considered constitutional, an aggravating factor within a capital sentencing scheme must properly limit the sentencer's discretion and provide clear and objective standards.