Woodson v. North Carolina

Background

Two men were convicted after taking part in an armed robbery during which a store cashier was killed and a customer was wounded. They and two accomplices were tried and found guilty of first-degree murder. Under North Carolina law at the time, a conviction for first-degree murder carried an automatic death sentence because the state had removed jury discretion after an earlier Supreme Court decision.

Reasoning

The Court asked whether a law that automatically imposes death on everyone convicted of first-degree murder is compatible with modern standards of decency. It looked at history, legislative trends away from mandatory death rules, and how juries actually behave. The plurality concluded that automatic death laws are contrary to the Eighth and Fourteenth Amendments because they prevent judges and juries from considering the individual offender, offer no standards to guard against arbitrary results, and do not allow meaningful review.

Real world impact

The Court reversed the state court’s approval of the sentences and ordered the cases sent back for new proceedings consistent with its opinion. In practice, people convicted under North Carolina’s mandatory law cannot be executed without a new sentencing process that allows individualized consideration and judicial review. The ruling also signals that other states using or considering automatic death penalties will need to revise their procedures.

Dissents or concurrances

A majority of the Court joined this plurality opinion, while Justices Brennan and Marshall agreed in the result for different reasons. Several Justices dissented, arguing the mandatory law should be upheld or that the Constitution does not forbid such statutes.