Abdul-Kamir v. Quarterman

Abdul-Kamir v. Quarterman, like several other cases before the court this year, was a victory for death penalty opponents. In each case, the individuals suffered from mental impairment, neurological issues, or difficult childhoods. Abdul-Kamir was convicted of murder and the judge instructed the jury to consider two questions at sentencing; whether his conduct was deliberate and came with a reasonable expectation of the victim's death and whether it was probable he would commit future crimes. While testimony was given regarding mitigating circumstances, including neurological damage and childhood neglect and abandonment, the prosecutor instructed the jury to consider only the facts. The Texas Court of Criminal Appeals denied Abdul-Kamir's claims, agreeing with the trial court. The Fifth Circuit Court further denied Abdul-Kamir's constitutional appeal, which relied upon Penry v. Lynaugh which required that juries hear mitigating evidence and be allowed a reasoned moral response.

The U.S. Supreme Court, as it historically has in cases of mitigating circumstances, decided in favor of Abdul-Kamir. The Supreme Court found that the Texas Court of Criminal Appeals had not applied Penry v. Lynaugh reasonably. The instructions given the Texas jury were so limiting that the jury could not give the required meaningful consideration to mitigating circumstances per law. The court was divided on the final decision, with a 5-4 split among the U.S. Supreme Court justices. While Texas no longer uses the jury instructions responsible in this case, Chief Justice Roberts called the court's findings revisionist and questioned prior similar court decisions.

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