Irving Davis (photo: Texas Department of Criminal Justice)
A federal appeals court upheld a Texas death row inmate's sentence, finding that state courts did not unreasonably allow evidence of his affiliation with Satanism because it was relevant to "future dangerousness."
Irving Alvin Davis was sentenced to death in 2002 after he was found guilty of sexually assaulting and killing 15-year-old Melissa Medina.
The backstory:
According to court documents, Davis, Medina and others were at a friend's house drinking and socializing when Davis said he was interested in Medina and attempted to grind on her while dancing. Medina was reportedly not interested in Davis' advances.
Later, the group left the home to walk Medina home. Court documents state Medina told the group that she could make it home when they approached an elementary school that she would normally cut through. As the group started to leave, Davis said he wanted to walk her the rest of the way home and ran after her.
Witnesses reported hearing "low growls followed by thumping noises and moaning." When Davis returned to the party, court documents state he had scratches that he said were from a fight with his mother.
Medina's unclothed body was found in the elementary school parking lot the next morning. Court documents state she had been sexually assaulted, beaten and her fingertips had been cut off in an attempt to hide evidence.
Davis was convicted of capital murder and sentenced to death in 2002. On appeal, the Texas Criminal Court of Appeals upheld the conviction, but ordered a new sentencing trial.
State introduces evidence of Davis' ties to Satanism at retrial
At the retrial, the state presented evidence that Davis had ties to Satanism, including books, writings and drawings from his prison cell. Davis was again sentenced to death and the sentencing was affirmed on appeal.
Davis files appeal claiming evidence of Satanism violated his First Amendment rights
Davis filed an appeal to the Fifth Circuit Court of Appeals claiming the introduction of evidence tying him to Satanism violated his First Amendment rights.
In the opinion, the court agreed with the Criminal Court of Appeals that Davis' ties to Satanism were relevant to his "future dangerousness."
What they're saying:
"Here, there were multiple writings and drawings from Davis that demonstrated that his affiliation with Satanism was relevant to future dangerousness," Judge Jerry Smith wrote.
Smith said the state had provided sufficient evidence that Davis' ties to Satanism were relevant when considering if he would commit violent acts.
"His writings show a frequent preoccupation and antipathy toward humanity in general, including several instances in which he wishes to enact some level of physical violence on others," Smith wrote. "Some of his drawings display violent and sexually explicit content, such as a drawing of a crying woman who is bound, gagged, and nearly naked and a drawing of woman with a slashed throat."
While the court ruled against Davis, it did not issue a blanket judgment that affiliation with a group or religion was admissible to the court.
Essentially, for such evidence to be admissible in court, it must be shown that it is tied to a legitimate issue and not used to punish or prejudice the defendant for belonging to a controversial group or religion.
The Source: Information in this article comes from an opinion from the U.S. Court of Appeals for the Fifth Circuit.