Was there sufficient evidence to support the especially heinous, atrocious or cruel aggravating factor?
Woodruff and Romano challenge the sufficiency of the evidence supporting the jury’s finding that Sarfaty’s murder was especially heinous, atrocious or cruel. The question presented is whether the evidence of what Woodruff and Romano did was sufficient to satisfy a constitutional aggravating circumstance. A constitutional aggravating factor channels and limits the capital “sentencer’s discretion in imposing the death penalty” in order to minimize sufficiently the risk of “wholly arbitrary and capricious action.” Maynard v. Cartwright, 486 U.S. 356, 362 (1988). It must provide a principled means by which a sentencer can distinguish between those murders warranting a death sentence and those that do not. See id. at 363. In Cartwright, the Supreme Court held that Oklahoma’s especially heinous, atrocious or cruel aggravating factor was unconstitutionally vague and overbroad because it failed to give a capital sentencer sufficient guidance–“an ordinary person could honestly believe that eve
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