Enmund v. Florida

458 U.S. 782 (1982)

Facts and Procedural History:

Petitioner was a participant in a robbery of two elderly persons at their farmhouse, in the course of which both victims were killed. His role was to wait in a car parked by the side of the road near the farmhouse and help the robbers. Petitioner was convicted of first-degree murder and robbery and sentenced to death. The Florida Supreme Court affirmed the decision of the trial court, holding that this was enough under Florida law to make petitioner a constructive aider and abettor and hence a principal in first-degree murder.

Issue Presented to the Court:

Is death a valid penalty under the Eighth and Fourteenth Amendments for one who neither took life, attempted to take life, nor intended to take life?

Outcome of the Case:

Following the “individualized” approach taken in Locket and Woodson, the Court focused on Petitioner’s culpability and considered relevant facts of character and record of the individual offender. Petitioner did not kill or intend to kill and therefore his culpability is different from that of the robbers who killed; it must be limited to his participation in the robbery, and his punishment must be tailored to his personal responsibility and moral guilt. The Court came to the conclusion that the death penalty in this case, in the absence of proof that Petitioner killed or attempted to kill, and noting that he neither intended nor contemplated that life would be taken, is “excessive” and “disproportionate” punishment prohibited by the Eighth and Fourteenth Amendment.