Robinson v. United States

Background

A man was tried for kidnapping a woman, moving her across state lines and holding her for ransom. Evidence showed he struck her twice on the head with an iron bar, gagged her with tape, and held her six days; her wounds had not healed when she was freed. At trial a jury recommended the death penalty and the judge imposed it. The Supreme Court agreed to decide only whether the statute allowed a death sentence when the victim was not "liberated unharmed."

Reasoning

The key question was whether "liberated unharmed" requires that injuries be permanent or still present at sentencing. The majority read "unharmed" to mean uninjured at the time of release and refused to add the word "permanent" or let the timing of appeals control punishment. Because the victim was injured when freed, the Court held the death penalty could be imposed and affirmed the sentence.

Real world impact

The decision lets prosecutors seek death when a kidnapped person was injured at the moment of release, even if wounds later heal before sentencing. It reduces the role of case delays in deciding whether death is available and narrows a defense argument that only permanent injuries bar execution.

Dissents or concurrances

A dissent argued the phrase is too vague, warned of perverse incentives and uncertainty, and would have vacated the death sentence and sent the case back for resentencing. Justice Murphy joined that view.