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Criminal Law Keyed to Kadish
Williams v. New York
Citation:
337 U.S. 241 (1949)Facts
Samuel Titto Williams was convicted of first-degree murder for killing a 15-year-old girl during a burglary. At trial, the jury found him guilty and recommended life imprisonment rather than the death penalty. However, during the sentencing phase, the judge considered a presentence investigation report that contained information about Williams’ involvement in approximately 30 uncharged burglaries, his maladjusted personality, and his being a “menace to society.” This information was not presented at trial and was not subject to cross-examination. Based on this additional information, the judge rejected the jury’s recommendation and imposed the death sentence. Williams appealed, arguing that the judge’s consideration of evidence not presented at trial violated his due process rights under the Fourteenth Amendment.
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