Woodson v. North Carolina

Jump to content

From Wikipedia, the free encyclopedia

(Redirected from Woodson v. North Carolina )

1976 U.S. Supreme Court case upholding the death penalty

1976 United States Supreme Court case

Gregg v. Georgia, Proffitt v. Florida, Jurek v. Texas, Woodson v. North Carolina, and Roberts v. Louisiana, 428 U.S. 153 (1976), is a landmark decision of the United States Supreme Court . It reaffirmed the Court's acceptance of the use of the death penalty in the United States , upholding, in particular, the death sentence imposed on Troy Leon Gregg . The set of cases is referred to by a leading scholar as the July 2 Cases, and elsewhere referred to by the lead case Gregg. The court set forth the two main features that capital sentencing procedures must employ in order to comply with the Eighth Amendment ban on "cruel and unusual punishments ". The decision essentially ended the de facto moratorium on the death penalty imposed by the Court in its 1972 decision in _Furman v. Georgia _ (1972). Justice Brennan 's dissent famously argued that "The calculated killing of a human being by the State involves, by its very nature, a denial of the executed person's humanity [...] An executed person has indeed 'lost the right to have rights.'"

Background

[(https://en.wikipedia.org/w/index.php?title=Gregg_v._Georgia&action=edit&section=1 "Edit section: Background")
]

Cases

[(https://en.wikipedia.org/w/index.php?title=Gregg_v._Georgia&action=edit&section=2 "Edit section: Cases")
]

All five cases share the same basic procedural history. After the Furman decision, the states of Georgia, Florida, Texas, North Carolina, and Louisiana amended their death penalty statutes to meet the Furman guidelines. Subsequently, the five named defendants were convicted of murder and sentenced to death in their respective states. The respective state supreme courts upheld the death sentence. The defendants then asked the U.S. Supreme Court to review their death sentence, asking the Court to go beyond Furman and declare once and for all the death penalty to be "cruel and unusual punishment" and thus in violation of the Constitution; the Court agreed to hear the cases.

In the July 2 Cases, the Court's goal was to provide guidance to states in the wake of Furman. In Furman only one basic idea could command a majority vote of the Justices: capital punishment, as then practiced in the United States, was cruel and unusual punishment because there were no rational standards that determined when it was imposed and when it was not. The question the Court resolved in these cases was not whether the death sentence imposed on each of the individual defendants was cruel, but rather whether the process by which those sentences were imposed was rational and objectively reviewable.

Capital punishment and the Eighth Amendment

[(https://en.wikipedia.org/w/index.php?title=Gregg_v._Georgia&action=edit&section=3 "Edit section: Capital punishment and the Eighth Amendment")
]

The defendants in each of the five cases urged the Court to go further than it had in Furman by holding once and for all that capital punishment was cruel and unusual punishment that violated the Eighth Amendment. However the Court responded that "The most marked indication of society's endorsement of the death penalty for murder is the legislative response to Furman." Both Congress and 35 states had complied with the Court's dictates in Furman by either specifying factors to be weighed and procedures to be followed when imposing a death sentence, or dictating that the death penalty would be mandatory for specific crimes. Furthermore, a referendum in California had overturned the California Supreme Court's earlier decision (_California v. Anderson _) holding that the death penalty violated the California constitution . The fact that juries remained willing to impose the death penalty also contributed to the Court's conclusion that American society did not believe in 1976 that the death penalty was unconstitutional.

The Court also found that the death penalty "comports with the basic concept of human dignity at the core of the [Eighth] Amendment". The death penalty serves two principal social purposes—retribution and deterrence. "In part, capital punishment is an expression of society's moral outrage at particularly offensive conduct". But this outrage must be expressed in an ordered fashion, for America is a society of laws. Retribution is consistent with human dignity, because society believes that "certain crimes are themselves so grievous an affront to humanity that the only adequate response may be the penalty of death". And although it is difficult to determine statistically how much crime the death penalty actually deters, the Court found that in 1976 there was "no convincing empirical evidence" supporting either the view that the death penalty is an effective deterrent to crime or the opposite view. Still, the Court could not completely discount the possibility that for certain "carefully contemplated murderers", "the possible penalty of death may well enter into the cold calculus that precedes the decision to act".

Finally, the Court considered whether the death penalty is "disproportionate in relation to the crime for which it is imposed". Although death is severe and irrevocable, the Court could not say that death was always disproportionate to the crime of deliberately taking human life. "It is an extreme sanction, suitable to the most extreme of crimes."

Historical disapproval of mandatory death sentences

[(https://en.wikipedia.org/w/index.php?title=Gregg_v._Georgia&action=edit&section=4 "Edit section: Historical disapproval of mandatory death sentences")
]

The Court was determined to simultaneously save capital punishment in the United States and impose some reasoned basis for carrying it out. That reasoning flows from the Eighth Amendment's cruel and unusual punishment clause. Although capital punishment, per se, was not found by the Court to be cruel and unusual, it must still be carried out in a manner consistent with the evolving standards of decency that mark the progress of a maturing society. In the Court's view, the country's history with capital punishment suggests that those evolving standards of decency could not tolerate a return to the mandatory death penalty for murder that had prevailed in medieval England.[_citation needed
_]

In 18th century Britain, the penalty for a vast number of serious crimes , including murder, was death. This rule traveled with the colonists to America, and was the law in all states at the time the Eighth Amendment was adopted in 1791. By then, however, a problem with the common-law mandatory death penalty had crept into the legal system. If the jury has only two options—convicting a defendant of murder, where the penalty is death, or acquitting the defendant outright—it has no vehicle to express the sentiment that the defendant should be punished somehow, but not executed. Faced with this dilemma, some juries would acquit the defendant in order to spare his life. Of course, this meant that an obviously guilty person would go free.[_citation needed
_]

To mitigate the harshness of the common-law rule, Pennsylvania divided murder into "degrees" in 1794. First-degree murder, a capital crime, was limited to all "willful, deliberate, and premeditated" murders. All other murder was second-degree murder, and not a capital crime. This development eased the tension created by the common-law mandatory death penalty, but some juries still refused to convict defendants who were clearly guilty of first-degree murder because that crime carried a mandatory death penalty.[_citation needed
_]

Recognizing that juries in capital cases found discretion in sentencing desirable, Tennessee, Alabama, and Louisiana afforded their juries this discretion in the 1840s. Finally, the jury could respond to mitigating factors about the crime or the criminal and withhold the death penalty even for convicted first-degree murderers. This development spread, and by 1900, 23 states and the federal government had discretionary sentencing in capital cases. Fourteen more states followed in the first two decades of the 20th century, and by 1963, all death-penalty jurisdictions employed discretionary sentencing.[_citation needed
_]

Decision of the Court

[(https://en.wikipedia.org/w/index.php?title=Gregg_v._Georgia&action=edit&section=5 "Edit section: Decision of the Court")
]

The Court set out two broad guidelines that legislatures must follow in order to craft a constitutional capital sentencing scheme:

• First, the scheme must provide objective criteria to direct and limit the death sentencing discretion. The objectiveness of these criteria must in turn be ensured by appellate review of all death sentences.
• Second, the scheme must allow the sentencer (whether judge or jury) to take into account the character and record of an individual defendant.

In Gregg, Proffitt, and Jurek, the Court found that the capital sentencing schemes of Georgia, Florida, and Texas, re

…