Many measures have been introduced in recent years to increase victim satisfaction with the criminal justice process. Victim participation at sentencing is one such measure that has met with enormous popularity across the United States. A series of United States Supreme Court cases dealing specifically with victim participation issues is detailed, with a primary focus on capital sentencing. An extensive critique of the authoritative case in this area, Payne v. Tennessee, is provided. The author offers some practical analysis of victim involvement and a word of caution about political forces at work in the victims' rights movement. Footnotes