Kansas v. Carr

The Eighth Amendment does not (1) require a court to instruct a jury engaged in capital sentencing that mitigating factors need not be proven beyond a reasonable doubt, or (2) require separate hearings for multiple defendants in a capital sentencing case.

The Kansas Supreme Court had vacated the death sentences of three defendants: two brothers, who had been convicted for their participation in a mass killing known as the "Wichita Massacre," and a defendant in a separate case who was convicted of murdering his co-conspirator and her boyfriend to cover the robbery of an elderly individual. For all defendants, the Kansas Supreme Court determined that the death sentences violated the 8th Amendment by neglecting to "affirmatively inform the jury that mitigating factors. . . [need not be proven] beyond a reasonable doubt." The Kansas Supreme Court also determined that the lower court's failure to sever sentencing proceedings infringed on the brothers' right to individualized sentencing, in violation of the 8th Amendment. The Court overturned the Kansas Supreme Court's rulings. The U.S. Supreme Court determined that the Eighth Amendment does not require courts to inform juries that mitigating factors need not be proven beyond a reasonable doubt. The Court also held that the Constitution did not require separation of proceedings.