Sattazahn v. Pennsylvania
The defendant was convicted of first-degree murder and given a life sentence after the jury hung at the sentencing phase. The conviction was reversed on appeal. After a new trial, the defendant was again convicted and this time, sentenced to death. The Supreme Court of Pennsylvania affirmed, holding that the constitutional guarantee against double jeopardy imposes no limitation on the power to retry a defendant who has succeeded in getting his first conviction set aside. Since there was no jury unanimity as to sentence during defendant’s first trial, there was no acquittal on the merits of the death penalty.
Questions Presented:
1. Whether the double jeopardy clause precludes imposing a sentence of death in a retrial, when, in the initial trial, a sentence of life imprisonment was imposed as a matter of law after the
capital sentencing jury deadlocked and was unable to reach a verdict.
2. Whether the Due Process Clause prohibits imposing a sentence of death on a defendant who, after being sentenced to life imprisonment as a matter of law following the sentencing jury's inability
to reach a verdict, obtained reversal of his conviction on appeal and is convicted again of capital murder in a retrial.
