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Boliek v. Missouri
Citations: 479 U.S. 903; 107 S. Ct. 302; 93 L. Ed. 2d 276; 55 U.S.L.W. 3255; 1986 U.S. LEXIS 4338Docket: 85-7087
Court: Supreme Court of the United States; October 14, 1986; Federal Supreme Court; Federal Appellate Court
The Supreme Court of the United States denied a petition for a writ of certiorari in the case of William Theodore Boliek, Jr. v. Missouri, with Justice Marshall dissenting. He argued that the death penalty is inherently cruel and unusual punishment, violating the Eighth and Fourteenth Amendments, and would vacate the Missouri Supreme Court's judgment that upheld Boliek's death sentence. Boliek was charged with murdering Jody Harless to prevent her from testifying about a robbery. He admitted to firing a non-fatal shot but claimed a co-participant fired the fatal shot. The prosecution presented hearsay evidence from two witnesses who testified that Harless expressed fear of Boliek before her death. The Missouri Supreme Court allowed this evidence, citing a hearsay exception for statements reflecting a declarant's mental state, though one judge dissented, arguing the victim's state of mind was not relevant to the case. Boliek contended that admitting this hearsay violated his Sixth Amendment rights under the Confrontation Clause. The dissent emphasized that the statements were used to assert the truth of Boliek's intent to kill, contrary to the principle that such evidence should not be admissible to prove the underlying facts of the case. The dissent noted that several jurisdictions restrict the use of victim state-of-mind evidence in homicide cases to prevent misuse. The evidence presented in this case was not admitted under a "firmly rooted" hearsay exception, as established in Ohio v. Roberts. Merely fitting hearsay evidence within a state exception does not satisfy the reliability standard of the Sixth Amendment. When evidence is used for purposes beyond its intended hearsay exception, the analysis must go beyond a superficial invocation of the rule. The evidence in question lacked independent reliability and was irrelevant to the defense's claim of accident. Its primary role, emphasized by the prosecutor, was to improperly suggest premeditation and intent, raising a significant issue regarding the Confrontation Clause. Therefore, the dissent suggests that certiorari should be granted based on precedents from various jurisdictions that support this viewpoint.