Ramdass v. Angelone
Annotate this Case
530 U.S. 156 (2000)
OCTOBER TERM, 1999
RAMDASS v. ANGELONE, DIRECTOR, VIRGINIA DEPARTMENT OF CORRECTIONS
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT
No. 99-7000. Argued April 18, 2000-Decided June 12, 2000
Petitioner Ramdass was sentenced to death in Virginia for the murder of Mohammed Kayani. Under Virginia law, a conviction does not become final until the jury returns a verdict and, some time thereafter, the judge enters a final judgment of conviction. At the time of the Kayani sentencing trial, a final judgment had been entered against Ramdass for an armed robbery at a Pizza Hut restaurant and a jury had found him guilty of an armed robbery at a Domino's Pizza restaurant, but no final judgment had been entered. The prosecutor argued future dangerousness at the Kayani sentencing trial, claiming that Ramdass would commit further violent crimes if released. The jury recommended death. After final judgment was entered on the Domino's conviction, the Kayani judge held a hearing to consider whether to impose the recommended sentence. Arguing for a life sentence, Ramdass claimed that his prior convictions made him ineligible for parole under Virginia's three-strikes law, which denies parole to a person convicted of three separate felony offenses of murder, rape, or armed robbery, which were not part of a common act, transaction, or scheme. The court sentenced Ramdass to death, and the Virginia Supreme Court affirmed. On remand from this Court, the Virginia Supreme Court again affirmed the sentence, declining to apply the holding of Simmons v. South Carolina, 512 U. S. 154, that a jury considering imposing death should be told if the defendant is parole ineligible under state law. The court concluded that Ramdass was not parole ineligible when the jury was considering his sentence because the Domino's crime, in which no final judgment had been entered, did not count as a conviction for purposes of the three-strikes law. Ultimately, Ramdass sought federal habeas relief. The District Court granted his petition, but the Court of Appeals reversed.
Held: The judgment is affirmed. 187 F.3d 396, affirmed.
JUSTICE KENNEDY, joined by THE CHIEF JUSTICE, JUSTICE SCALIA, and JUSTICE THOMAS, concluded that Ramdass was not entitled to a jury instruction on parole ineligibility under Virginia's three-strikes law. Pp.165-178.
(a) Whether Ramdass may obtain relief under Simmons is governed by the habeas corpus statute, 28 U. S. C. § 2254(d)(1), which forbids relief unless a state-court adjudication of a federal claim is contrary to, or an unreasonable application of, clearly established federal law as determined by this Court. The Virginia Supreme Court's ruling here was neither contrary to Simmons nor an unreasonable application of its rationale. Pp. 165-166.
(b) Simmons created a workable rule. The parole-ineligibility instruction is required only when, assuming the jury fixes a life sentence, the defendant is ineligible for parole under state law. The instruction was required in Simmons because it was legally accurate. However, that is not the case here, for the Virginia Supreme Court's authoritative determination is that Ramdass was not parole ineligible when the jury considered his sentence. Material differences exist between this case and Simmons: The Simmons defendant had conclusively established his parole ineligibility at the time of sentencing and Ramdass had not; a sentence had been imposed for the Simmons defendant's prior conviction and he pleaded guilty, while the Domino's case was tried to a jury and no sentence had been imposed; and the grounds for challenging a guilty plea in the Simmons defendant's State are limited. Ramdass' additional attempts to equate his case with Simmons do not refute the critical point that he was not parole ineligible as a matter of state law at the time of his sentencing trial. Pp. 166-169.
(c) Extending Simmons to cover situations where it looks like a defendant will turn out to be parole ineligible is neither necessary nor workable, and the Virginia Supreme Court was not unreasonable in refusing to do so. Doing so would require courts to evaluate the probability of future events in cases where a three-strikes law is the issue. The States are entitled to some latitude in this field, for the admissibility of evidence at capital sentencing is an issue left to them, subject to federal requirements. Extending Simmons would also give rise to litigation on a peripheral point, since parole eligibility may be only indirectly related to the circumstances of the crime being considered and is of uncertain materiality. The State is entitled to some deference in determining the best reference point for making the ineligibility determination. Virginia's rule using judgment in the Domino's case to determine parole ineligibility is not arbitrary by virtue of Virginia's also allowing the prosecutor to introduce evidence of Ramdass' unadjudicated prior bad acts to show future dangerousness. Public opinion polls showing the likely effect of parole ineligibility on jury verdicts cast no doubt upon the State's rule. Ramdass' claim is based on the contention that it is inevitable that a judgment of conviction would be entered for his Domino's crime, but it is a well-established practice for Virginia