Woodson v. North Carolina

Supreme Court of the United States · 1976 · Criminal Law

Criminal LawDeath PenaltyEighth AmendmentSentencingmandatory death penaltyfirst-degree murderEighth AmendmentFourteenth Amendment

Facts

Petitioners Woodson and Waxton participated with two others in an armed robbery of a convenience store during which the cashier was killed and a customer was seriously wounded. The prosecution's evidence showed that Waxton and Tucker entered the store while Woodson and Carroll remained in the car as lookouts, and that Waxton fatally shot the cashier; the petitioners' testimony largely agreed except Waxton claimed Tucker was the shooter. Tucker and Carroll testified for the prosecution after being allowed to plead guilty to lesser offenses, while Waxton was not permitted to plead guilty to lesser offenses and Woodson maintained he had been coerced. After petitioners were found guilty of first-degree murder, North Carolina law required the court to impose death automatically.

Issue

Does North Carolina's statute requiring the death penalty for every person convicted of first-degree murder violate the Eighth and Fourteenth Amendments? More specifically, may a State constitutionally impose death mandatorily for a broad category of homicides without individualized consideration of the offender and the offense?

Rule

The Eighth and Fourteenth Amendments forbid a mandatory death sentence for a broad category of homicidal offenses. In capital cases, the Constitution requires a sentencing process that reflects contemporary standards of decency, does not simply mask arbitrary jury power, and permits particularized consideration of the character and record of the individual offender and the circumstances of the particular offense before death is imposed.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Ohio enacts a statute providing that every person convicted of first-degree murder must be sentenced to death. The law does not allow a separate sentencing hearing or any consideration of mitigating evidence.

If challenged under the Eighth and Fourteenth Amendments, how should a court most likely rule?

Explanation. A mandatory death sentence for a broad category of homicide is unconstitutional. The majority held that such schemes depart from contemporary standards of decency, do not genuinely solve arbitrariness, and fail to permit particularized consideration of the defendant's character, record, and the circumstances of the offense before death is imposed. The fact that death may constitutionally be imposed in some murder cases does not make an automatic scheme valid.