Fifth Circuit reviews punishment retrial where Satanism affiliation was introduced by prosecutors.
When Irving Alvin Davis was sentenced to death in Texas for the 2002 rape and murder of 15-year-old Melissa Medina, the brutality of the crime itself was not in dispute. Medina was sexually assaulted, strangled, and dismembered. Davis later admitted he killed her because he feared she would report the assault. Nothing in the trial record suggested the killing was ritualistic or tied to religious practices.
The unusual feature came years later, at Davis’s 2008 punishment retrial. Prosecutors introduced evidence that Davis had identified as a Satanist in prison, possessed literature associated with the Church of Satan, and produced writings and drawings that emphasized violent themes. A state expert testified that some strains of Satanism endorse violence, while the defense countered that the church formally opposes it. The state urged jurors to consider this affiliation in deciding whether Davis posed a continuing threat.
This strategy placed the case at the intersection of capital punishment and First Amendment law. In Dawson v. Delaware (1992), the U.S. Supreme Court ruled that evidence of a defendant’s abstract beliefs cannot be admitted at sentencing if it has no relevance beyond inflaming jurors. The Court has allowed such evidence only when it directly relates to sentencing issues like motive or future dangerousness. Davis’s lawyers argue that because his crime lacked religious elements, the evidence of Satanism was constitutionally irrelevant.
The Fifth Circuit has now agreed to review that argument. If the court concludes that the evidence improperly influenced the jury, the likely remedy would not overturn the conviction but instead vacate the death sentence and order a new punishment trial. A new jury would then determine whether Davis should face life without parole or execution.
The case highlights a rarely examined question: when does a defendant’s belief system cross the line from constitutionally protected thought to relevant sentencing evidence? With briefing underway, the Fifth Circuit will soon decide how that balance applies in Davis’s case.
Tags: Fifth Circuit, Irving Alvin Davis, death penalty, Satanism evidence, Dawson v. Delaware