Court Upholds Sentencing Review Standards for Capital Cases

The Tennessee Supreme Court, in a 3-2 decision, has upheld a death sentence for a Memphis-area man who was convicted of first-degree felony murder. While the entire court agreed that Corinio Pruitt was guilty, the dissenting justices would have modified the sentence to life without parole. The majority concluded that the sentence of death was not imposed arbitrarily, that the evidence supported the jury’s finding of guilt, and that the sentence was not excessive or disproportionate. In their separate opinion, Justice William C. Koch Jr. and Justice Sharon G. Lee wrote that comparing all first-degree murder cases would be more consistent with the Tennessee law that requires proportionality review and with the rule that capital punishment is not appropriate for all murders but is reserved for only the most heinous murders and the most dangerous murderers. The two dissenting justices also pointed to a 2007 American Bar Association study of Tennessee’s death penalty, which said that the limited pool of cases the court adopted in 1997 undercut the purpose of proportionality review.