TYLER, Texas (KETK) – In one of the most prominent Smith County court cases this decade, Gustavo Zavala-Garcia pled guilty to the murder of Kayla Gomez on Thursday in a plea deal struck with the District Attorney’s Office. He was sentenced to life in prison for the deal instead of being executed.
In a statement, Smith County DA Jacob Putman said that the reason for the deal was due to a 2017 decision by the Supreme Court that severely limits the State’s ability to execute those who are found to be intellectually disabled.
He was clearly displeased with the decision in a press conference after the plea hearing and said: “The Supreme Court doesn’t like the death penalty.”
The following is a look into what the Supreme Court case was and how certain political circumstances may have influenced the decision.
Moore v. Texas
The case started as a murder trial in 1980 when Bobby James Moore was convicted of shooting a 70-year-old store clerk, James McCarble, in Houston. Moore was sentenced to death for the killing.
Over the next three decades, Moore would appeal saying that he fell in the range of having an intellectual disability and that him being executed would violate his eighth amendment right of “cruel and unusual punishment.” He also argued that the jury was using outdated standards in determining if he had a disability and that his IQ score fell into the range of having a disability.
In 2002, the Supreme Court ruled in a similar case (Atkins v. Virginia) that the execution of intellectually-disabled people violated the Constitution. However, they allowed the states to be able to define mental disabilities on their own.
The Texas Court of Criminal Appeals disagreed with Moore’s argument and the case went before the Supreme Court in late 2016.
The Political Circumstances
The case was held just three weeks after the 2016 election when President Trump pulled an upset victory over Hillary Clinton.
At the time, there were only eight justices to hear the case because the Senate refused to hold a confirmation vote on President Obama’s nomination of Merrick Garland to replace the late Antonin Scalia.
The swing vote would lie with Justice Anthony Kennedy, who could potentially deadlock the case in a 4-4 vote. Kennedy would retire from the Court just over one year later.
The Court held that the State of Texas did not use a modern standard to define intellectual disability for defendants. This was due to mostly the jury making the decision rather than medical experts.
This ruling greatly widened the range for an intellectual disability to be diagnosed to keep someone from being executed.
Kennedy as the swing vote joined the majority opinion and kept the case from being deadlocked. If that had happened, the lower court ruling would stand and the old test would remain in place.
Impact on Zavala-Garcia Case
Putman said in court and in the press conference that this new standard was the reason that the death penalty was not sought after.
A doctor for the prosecution, Timothy Proctor, examined Zavala-Garcia and found that he was intellectually disabled based on the new standard.
“If there was any legal way to ensure that Mr. Zavala-Garcia would face the death penalty, I would persist. However, I took an oath to uphold the rule of law.”Jacob Putman
Due to this, the only sentencing option available under Texas law was life in prison without the possibility of parole.
With this in mind, Putman said that while he was not pleased with not being able to seek an execution, the plea was the only outcome possible. Putman told this to Kayla’s family before the hearing and said in the press conference while they were not happy that there would be no execution, they understood.
“He will never be released. He will die in prison.”Jacob Putman