Uploaded February 2025 | Updated September 2026, 2 weeks ago
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Lowenfield v. Phelps - United States Supreme Court
484 U.S. 231, 108 S.Ct. 546, 98 L.Ed.2d 568 (1988)
The sixth amendment guarantees criminal defendants the right to a fair trial, including the right to an impartial jury. A trial court compromises this right when it engages in conduct that coerces a jury to render a guilty verdict.
In Lowenfield versus Phelps, the Supreme Court reviewed a trial court's conduct to determine whether it was coercive.
A Louisiana jury convicted Leslie Lowenfield of first degree murder. During the trial's sentencing phase, the jury had to decide whether to recommend a sentence of death or a sentence of life in prison. The judge instructed the jury that if it was unable to reach a unanimous verdict, the court would sentence Lowenfield to life in prison as required by state law.
After deliberating for several hours, the jury informed the judge that they were having trouble reaching a verdict. The judge polled the jurors, asking them whether they believed that further deliberations would be helpful.
Eight jurors answered yes, and four jurors answered no. So the judge instructed the jurors to keep deliberating.
Sometime later, the jury sent another note to the judge, prompting the judge to pull the jury a second time. This time, all but one juror indicated that further deliberations would be beneficial.
The judge read a supplemental instruction, charging the jurors to reexamine their own views about sentencing, but admonishing them not to abandon their sincerely held views to reach a unanimous agreement.
After another thirty minutes of deliberation, the jury unanimously recommended a death sentence.
After exhausting his state remedies, Lowenfield filed a federal habeas petition. The district court denied the petition, and the fifth circuit affirmed.
The Supreme Court granted cert.
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Get more case briefs explained with Quimbee. Quimbee has over 42,700 case briefs (and counting) keyed to 988 casebooks ► quimbee.com/case-briefs-overview
Lowenfield v. Phelps - United States Supreme Court
484 U.S. 231, 108 S.Ct. 546, 98 L.Ed.2d 568 (1988)
The sixth amendment guarantees criminal defendants the right to a fair trial, including the right to an impartial jury. A trial court compromises this right when it engages in conduct that coerces a jury to render a guilty verdict.
In Lowenfield versus Phelps, the Supreme Court reviewed a trial court's conduct to determine whether it was coercive.
A Louisiana jury convicted Leslie Lowenfield of first degree murder. During the trial's sentencing phase, the jury had to decide whether to recommend a sentence of death or a sentence of life in prison. The judge instructed the jury that if it was unable to reach a unanimous verdict, the court would sentence Lowenfield to life in prison as required by state law.
After deliberating for several hours, the jury informed the judge that they were having trouble reaching a verdict. The judge polled the jurors, asking them whether they believed that further deliberations would be helpful.
Eight jurors answered yes, and four jurors answered no. So the judge instructed the jurors to keep deliberating.
Sometime later, the jury sent another note to the judge, prompting the judge to pull the jury a second time. This time, all but one juror indicated that further deliberations would be beneficial.
The judge read a supplemental instruction, charging the jurors to reexamine their own views about sentencing, but admonishing them not to abandon their sincerely held views to reach a unanimous agreement.
After another thirty minutes of deliberation, the jury unanimously recommended a death sentence.
After exhausting his state remedies, Lowenfield filed a federal habeas petition. The district court denied the petition, and the fifth circuit affirmed.
The Supreme Court granted cert.
Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here: quimbee.com/cases/lowenfield-v-phelps
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