Kansas v. Carr

Kansas v. Carr, 577 U.S. 108 (2016), was a case in which the Supreme Court of the United States clarified several procedures for sentencing defendants in capital cases. Specifically, the Court held that judges are not required to affirmatively instruct juries about the burden of proof for establishing mitigating evidence, and that joint trials of capital defendants "are often preferable when the joined defendants’ criminal conduct arises out of a single chain of events". This case included the last majority opinion written by Justice Antonin Scalia before his death in February 2016.

Background

This case involved two separate murder cases that were consolidated on appeal. Sidney Gleason was initially sentenced to death for the alleged murder of a co-conspirator and that co-conspirator's boyfriend to conceal evidence of a robbery. In a separate case, brothers Reginald and Jonathan Carr were jointly sentenced to death for the rape, kidnapping, and murder of five individuals after a crime spree in Wichita, Kansas, that ultimately became known as the Wichita Massacre. In both cases, the Kansas Supreme Court reversed the death sentences; the court ruled that the juries should have been affirmatively instructed that mitigating circumstances need not be proved beyond a reasonable doubt. Additionally, the Kansas Supreme Court ruled that the Carrs should have been tried separately. The Kansas attorney general Derek Schmidt filed an appeal to the United States Supreme Court, which granted certiorari to review the Kansas Supreme Court's rulings.