Nicholas v. Fenton

How later courts describe this case

• affirming denial of self-representation based on finding of mental illness even though defendant competent to stand trial
• upholding death penalty under 1977 statute prescribing aggravating and mitigating circumstances in bifurcated system
• "vileness" and "dangerousness" predicates for imposition of the death penalty do not impermissibly fail to guide the jury's discretion
• state constitutional prohibition against ex post facto laws invalidated the death sentence when the defendant committed the crime at a time the Tennessee death penalty statute was unconstitutional
• “Battery which, qualitatively and quantitatively, is more culpable than the minimum necessary to accomplish the act of murder.”
• no ex post facto violation because changes to death penalty statute were procedural and ameliorative
• employer implemented changes five weeks after the expiration of the contract