Oregon v. Guzek
Guzek was convicted of murder and sentenced to death. On appeal, the Oregon Supreme Court affirmed his conviction but vacated the sentence and remanded to the trial court for a new sentencing trial. Guzek was sentenced to death again. He appealed, and the Oregon Supreme Court again vacated the sentence and remanded for a third sentencing trial. During the third sentencing trial, the trial judge failed to instruct the jury about a "true-life" sentencing option as an alternative to the death penalty. Because of this error, the Oregon Supreme Court once again vacated Guzek's sentence and remanded for a new sentencing trial. The court also addressed other issues that might be raised on remand, including whether alibi evidence that had been admitted during the guilt phase of the trial should be admitted during the sentencing phase.
At the fourth sentencing trial, Guzek sought to admit transcripts of the testimonies of his mother and grandfather stating that he was with them when the murder took place. The trial court did not admit the transcripts, concluding that they only addressed the issue of Guzek’s guilt and were not relevant to the sentence Guzek should receive. On appeal, the Oregon Supreme Court rejected this reasoning and stated that the trial court should admit the transcripts in Guzek’s fourth penalty-phase proceeding because they could be considered mitigating evidence.
Question Presented:
Can a defendant facing the death penalty introduce “alibi evidence” during the sentencing phase of a trial?
