Woodson v. North Carolina

428 U.S. 280 (1976)

Facts and Procedural History:

Petitioners were convicted of first-degree murder as the result of their participation in an armed robbery of a convenience food store where the cashier was killed and a customer was seriously wounded. The Supreme Court of North Carolina upheld their sentences under the new North Carolina statute, which required death sentences for all defendants convicted of that crime. Certiorari was granted to challenge the statute's constitutionality.

Issue Presented to the Court:

Does North Carolina's statute imposing mandatory death sentence for a first-degree murder violate the Eighth and Fourteenth Amendments?

Outcome of the Case:

The Court concludes, that mandatory death penalties are incompatible with contemporary values and cannot be applied in consistency with requirement that the State's power to punish "be exercised within the limits of civilized standards."

Another deficiency of North Carolina's mandatory death sentence statute is its failure to provide a constitutionally tolerable response to Furman v. Georgia's rejection of jury discretion in the imposition of capital sentences.
Finally, the Eight Amendment requires consideration of various aspects of the character of the individual offender and the circumstances of the particular offense as a “constitutionally indispensable part of the process of imposing the ultimate punishment of death”. The North Carolina statute did not allow such a particularized approach.
Therefore, North Carolina's mandatory death penalty statute is in violation of the Eighth and Fourteenth Amendments and must be set aside.