People v. LaValle
People v. LaValle was a 2004 ruling by the New York Court of Appeals, the state’s highest court. The court held that New York’s death penalty statute was unconstitutional because of how juries were instructed about deadlock.
Stephen S. LaValle, a paroled sex offender, raped, molested, and murdered high-school track coach Cynthia Quinn in 1997. He was tried in Suffolk County, convicted of first-degree murder, and sentenced to death in 1999. LaValle argued two main points: one juror was biased against him from the start, and the emotional testimony from Quinn’s husband should not have weighed so heavily. The Court of Appeals upheld the conviction but struck down the death sentence, finding that the law on what happens if a jury deadlocks (CPL 400.27(10)) violated the New York Constitution.
The court said the deadlock instruction could pressure jurors to choose life without parole to avoid the chance of parole after 20 years, which violated due process. The court allowed some notice about deadlock but said only the legislature could provide a proper instruction. LaValle was remanded for resentencing under new rules, and he was sentenced to life in prison without the possibility of parole. The decision also invalidated the death sentences of other inmates on death row.
In 2007, there were discussions about restoring a death penalty for certain crimes, but no law was passed. That year the Court of Appeals decided People v. John Taylor, addressing the last death-row inmate and rejecting attempts to make an exception to LaValle.
This page was last edited on 2 February 2026, at 08:50 (CET).