Enmund v. Florida

Background

Earl Enmund was tried for two murders that occurred during a 1975 robbery of an elderly couple, Thomas and Eunice Kersey. Two co-defendants entered the house, shots were fired, and the Kerseys were killed. Enmund sat in a nearby car and was convicted under Florida's felony-murder and accomplice rules; a jury recommended death and the trial judge sentenced him to death. The Florida Supreme Court affirmed the conviction and sentence, accepting the inference that Enmund was the getaway driver and a principal under state law.

Reasoning

The central question the Court addressed was whether the Constitution allows execution of someone who aided a felony but did not kill, attempt to kill, or intend that a killing occur. The majority examined legislative choices, jury sentencing patterns, and whether the death penalty serves deterrence or retribution for such a defendant. The Court concluded that imposing death under those circumstances is disproportionate and violates the Eighth and Fourteenth Amendments. The Court stressed individualized punishment tied to a defendant's personal culpability and reversed the judgment upholding Enmund's death sentence, remanding for further proceedings consistent with its ruling.

Real world impact

The decision affects people convicted as accomplices under felony-murder rules, especially alleged getaway drivers or planners who did not pull the trigger or intend death. States that authorized capital sentences for nontriggermen must reconsider or limit death penalties in light of the Court's proportionality analysis. The ruling requires sentencers to focus on the defendant's intent and role before imposing death.

Dissents or concurrances

Justice Brennan joined the judgment but reiterated his view that capital punishment is always unconstitutional. Justice O'Connor dissented, joined by three Justices, arguing the decision improperly displaces state rules and disagreed with the majority's constitutional conclusion.