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State v. Hayward

Citations: 963 P.2d 667; 327 Or. 397; 1998 Ore. LEXIS 593Docket: CC 10-94-08860; SC S43096

Court: Oregon Supreme Court; July 24, 1998; Oregon; State Supreme Court

Original Court Document: View Document

Narrative Opinion Summary

The Supreme Court of the State of Oregon reviewed and affirmed the conviction and death sentence of a defendant involved in a gruesome robbery-murder case. The defendant and accomplices plotted to rob a store and included murder in their plans, motivated partly by their affinity for death metal music and satanism. During the crime, they brutally attacked and killed one victim while severely injuring another, who managed to escape and later identified her attackers. The defendant was found guilty of multiple counts of aggravated murder among other charges, and the court imposed the death penalty. On appeal, the defendant challenged the plea bargaining process, arguing the lack of a formal policy denied him constitutional rights. However, the court found the plea bargaining policy was guided by set criteria. The court also addressed the admissibility of motive evidence related to satanism and death metal music, which was upheld as relevant. Jury instructions on coexisting intents were deemed appropriate, and the defendant’s objections were overruled. The court also admitted victim impact evidence during sentencing, finding no ex post facto violation. Ultimately, the court affirmed the conviction and death sentence, dismissing additional constitutional challenges to the state's death penalty scheme.

Legal Issues Addressed

Admissibility of Motive Evidence

Application: The court allowed evidence related to death metal music and satanism as it was relevant to establishing the defendants' motive for committing murder.

Reasoning: The evidence was found pertinent to understanding the brutality of the attacks and the defendants' intentions.

Automatic Review of Death Sentences

Application: The Supreme Court of Oregon reviewed the case automatically due to the imposition of a death sentence, affirming the conviction and sentence.

Reasoning: The Supreme Court of the State of Oregon, on July 24, 1998, affirmed the judgment of conviction and death sentence for Michael James Hayward.

Jury Instruction on Coexisting Intents

Application: The court held that the jury instruction did not improperly comment on the evidence or mislead the jury about the state's burden of proof.

Reasoning: The instruction in question did not direct the jury on how the evidence related to any crime's elements or suggest that the state met its burden of proof.

Plea Bargaining Policy in Capital Cases

Application: The court found no evidence of improper motives or arbitrariness in the Lane County District Attorney's plea bargaining policy, which follows established guidelines.

Reasoning: The Lane County District Attorney's approach to plea bargaining, particularly in death penalty cases, is guided by established criteria and an assessment of evidence strengths and weaknesses.

Victim Impact Evidence

Application: The court allowed victim impact evidence during the penalty phase, which did not violate ex post facto laws as it was permissible under the 1995 amendment.

Reasoning: The trial court overruled the objection, allowing David Wall to testify about his family and the impact of Frances Wall's death.