Roberts v. Louisiana
The Supreme Court struck down Louisiana's mandatory death penalty law, ruling that automatically sentencing every first-degree murderer to death violates the Eighth and Fourteenth Amendments.
The decision, issued alongside a similar ruling on North Carolina's law, means states cannot solve the unpredictability of jury-imposed death sentences simply by making death automatic upon conviction; some individualized consideration of the offender and the offense is constitutionally required.
How it got here: A Louisiana jury convicted the petitioner and the trial judge imposed the mandatory death sentence; the Louisiana Supreme Court affirmed, and the U.S. Supreme Court agreed to review the case.
The Case in Depth
What happened
A gas station attendant in Lake Charles, Louisiana, was shot and killed during an armed robbery in 1973. The petitioner was one of four men arrested, and was convicted by a jury of first-degree murder. Under Louisiana's post-Furman law, a first-degree murder conviction automatically triggered a death sentence, with the trial judge required to impose it regardless of any individual circumstances.
The question before the Court
Could Louisiana automatically sentence every person convicted of first-degree murder to death, without letting the jury weigh that person's individual circumstances?
Why it matters
Louisiana's death sentence in this case was set aside, and the ruling forced Louisiana and other states with similar mandatory death penalty schemes to rewrite their capital sentencing laws to allow juries to weigh individual circumstances, reshaping death penalty procedure nationwide.
What changes now
The death sentence imposed on the petitioner was set aside, and the case was sent back to Louisiana courts for further proceedings consistent with the Court's ruling that mandatory capital sentencing is unconstitutional. Louisiana, like North Carolina, would need to revise its capital sentencing procedures to allow for individualized consideration of mitigating and aggravating factors. This is a final merits decision, not a temporary order.
What this does not decide
The Court did not decide that the death penalty itself is unconstitutional; a majority upheld capital punishment generally in the companion case Gregg v. Georgia. This ruling addresses only the constitutionality of making death an automatic, mandatory sentence upon conviction.
Concurrences and dissents
Concurrence — Justice Brennan
Justice Brennan concurred only in the judgment, relying on his dissent in Gregg v. Georgia that the death penalty is always cruel and unusual punishment under the Eighth and Fourteenth Amendments, regardless of the sentencing procedure used.
Concurrence — Justice Marshall
Justice Marshall concurred only in the judgment, reiterating his view from his Gregg v. Georgia dissent that the death penalty itself is cruel and unusual punishment forbidden by the Eighth and Fourteenth Amendments.
Dissent — Justice Burger
Chief Justice Burger dissented for the reasons in his Furman v. Georgia dissent, without elaborating further in this case.
Dissent — Justice White
Justice White argued that Louisiana's mandatory death penalty was sufficiently different from the discretionary scheme struck down in Furman, because it eliminated the jury's formal discretion to withhold capital punishment. He also disagreed with the plurality's new requirements for individualized sentencing consideration and a separate sentencing proceeding, arguing McGautha v. California had already rejected such claims, and that legislatures could rationally choose mandatory sentencing.
Dissent — Justice Blackmun
Justice Blackmun dissented for the reasons stated in his Furman v. Georgia dissent and the other Furman dissents he had joined, without adding new reasoning specific to this case.
How the Court got there
The legal reasoning, step by step
- The Court asked whether Louisiana's mandatory death sentence, imposed automatically on every first-degree murder conviction, satisfied the requirement from Furman v. Georgia that death sentencing be guided by standards that prevent arbitrary and capricious results.
- The Court found that narrowing the definition of the capital crime to five specific categories of killing did not solve this problem, because history showed that legislatures which tried narrowing capital offenses eventually abandoned that approach as insufficient and moved to individualized sentencing instead.
- The Court examined Louisiana's system of 'responsive verdicts,' under which juries in every first-degree murder trial were instructed on lesser verdicts like second-degree murder and manslaughter even without evidentiary support, and found this created an unregulated, standardless way for jurors to informally avoid the mandatory death penalty by disregarding their instructions.
- Because this responsive-verdict practice offered no real standards to guide juries and no meaningful appellate review of jury decisions, the Court concluded it replicated the arbitrariness Furman condemned, rather than eliminating it.
- Applying the same reasoning it used for North Carolina's similar law, the Court concluded that a mandatory death sentence scheme that ignores the character of the offender and the details of the offense cannot be reconciled with the Eighth Amendment's evolving standards of decency.
Doctrinal impact
Cases affected by this decision
Reaffirms Furman v. Georgia (408 U.S. 238)
The Court relied on Furman's requirement that death sentencing avoid arbitrary and capricious results.
Reaffirms Woodson v. North Carolina
The Court applied the same reasoning used to strike down North Carolina's mandatory death penalty law to Louisiana's law.