Woodson v. North Carolina

PETITIONER: Woodson
RESPONDENT: North Carolina
LOCATION: North Carolina State Capitol

DOCKET NO.: 75-5491
DECIDED BY: Burger Court (1975-1981)
LOWER COURT: North Carolina Supreme Court

CITATION: 428 US 280 (1976)
ARGUED: Mar 31, 1976
DECIDED: Jul 02, 1976

ADVOCATES:
Anthony G. Amsterdam - Argued the cause for the petitioners
Robert H. Bork - Argued the cause for the United States as amicus curiae
Sidney S. Eagles, Jr. - Argued the cause for the respondent
William E. James - argued for the State of California, as amicus curiae

Facts of the case

The state of North Carolina enacted legislation that made the death penalty mandatory for all convicted first-degree murderers. Consequently, when James Woodson was found guilty of such an offense, he was automatically sentenced to death. Woodson challenged the law, which was upheld by the Supreme Court of North Carolina.

This case is one of the five "Death Penalty Cases" along with Gregg v. Georgia, Jurek v. Texas, Proffitt v. Florida, and Roberts v. Louisiana.

Question

Did the mandatory death penalty law violate the Eighth and Fourteenth Amendments?

Media for Woodson v. North Carolina

Audio Transcription for Oral Argument - March 31, 1976 in Woodson v. North Carolina

Audio Transcription for Opinion Announcement - July 02, 1976 in Woodson v. North Carolina

Potter Stewart:

The next case to announce this morning, the fourth case is 75-5491, James Tyrone Woodson and Luby Waxton petitioners against the state North Carolina, respondent, a case which is here on writ of certiorari to the Supreme Court of North Carolina.

The question in this case is whether the imposition of a death sentence for the crime of first-degree murder under the law of North Carolina violates the Eighth and Fourteenth Amendments of the Constitution.

The petitioners were convicted of first-degree murder and mandatorily sentenced to death as the result of their participation in an armed robbery of a convenience food store, in the course of which the cashier was killed.

The Supreme Court of North Carolina affirmed the judgments and we granted certiorari to consider the claim that the imposition of the death sentences in this case amount to cruel and unusual punishment in violation of the Constitution.

The petitioner's first and most basic argument is that the imposition of the death penalty under any circumstances at any time is cruel and unusual punishment.

We reject this argument for the reasons stated in the opinions that have just been announced.

At the time of this Court's decision in the Furman case Furman against Georgia in 1972, North Carolina law provided that, in cases of first-degree murder, the jury, in its unbridled discretion, could choose whether the convicted defendant should be sentenced to death or to life imprisonment.

After the Furman decision, the Supreme Court of North Carolina held unconstitutional the provision of the death penalty statute that gave the jury that option, but the State Supreme Court held further that this provision was severable so that the statute survived as a mandatory death penalty law.

The North Carolina General Assembly, two years later in 1974, followed the court's lead and enacted a new statute that was essentially unchanged from the old one, except that it made the death penalty mandatory.

It was under this statute that the petitioners, who committed their crime on June 3, 1974, were tried, convicted, and sentenced to death.

North Carolina, unlike Florida, Georgia, and Texas, has thus responded to the Furman decision by making death the mandatory sentence for all persons convicted of first-degree murder.

In ruling on the constitutionality of the sentences imposed on the petitioners under this North Carolina statute, the Court now addresses for the first time, the question whether a death sentence returned pursuant to a law imposing a mandatory death penalty for a broad category of homicidal offenses, constitutes cruel and unusual punishment within the meaning of the Eighth and Fourteenth Amendments.

It is settled that the Eighth Amendment stands to assure that State's power to punish is "exercised within the limits of civilized standards."

Central to the application of the Amendment, therefore, is a determination of contemporary standards regarding the infliction of punishment.

At the time the Eighth Amendment was adopted in 1791, the States uniformly followed the common law practice of making death the exclusive and mandatory sentence for certain specified offenses.

Although, the range of capital offenses in the American Colonies was quite limited in comparison to the more than 200 offenses then punishable by death in England, the Colonies at the time of the Revolution imposed death sentences on all persons convicted of any of a considerable number of crimes, typically including at a minimum, murder, treason, piracy, arson, rape, robbery, burglary, and sodomy.

But almost from the outset, jurors reacted unfavorably to the harshness of mandatory death sentences.

The States initially responded to this expression of public dissatisfaction with mandatory statutes by limiting the classes of capital offenses.

This reform, however, left unresolved the problem posed by the not infrequent refusal of jurors to convict even murderers rather than to subject them to automatic death sentences.

In 1794, Pennsylvania attempted to alleviate the undue severity of the law by confining the mandatory death penalty to "murder of the first degree" and within a generation that practice spread to most of the States.

But Juries continued to find the death penalty inappropriate in a significant number of first-degree murder cases, and refused to return guilty verdicts for that crime.

The inadequacy of distinguishing between murderers solely on the basis of legislative criteria soon led the States to grant juries sentencing discretion in capital cases.

Tennessee, in 1838, followed by Alabama, in 1841, and Louisiana, in 1846, were the first States to abandon mandatory death sentences even for first-degree of murder, in favor of discretionary death penalty statutes.

By the turn of this century, 23 States and the Federal Government had made death sentences discretionary for first-degree murder.

And during the next two decades, 14 additional States replaced their mandatory death penalty statutes.

By 1963, all of the remaining jurisdictions had replaced their automatic death penalty statutes with discretionary jury sentencing.

The history of mandatory death penalty statutes in the United States thus reveals that the practice of sentencing to death all persons convicted of a particular offense, even first-degree of murder, had been totally rejected years before the Furman case was decided in this Court.

The two crucial indicators of evolving standards of decency respecting the imposition of punishment in our society, jury determinations and legislative enactments, both therefore point conclusively to the repudiation in our country of mandatory death sentences.

Although this Court has never ruled on the constitutionality of mandatory death penalty statutes, it has on several occasions, dating back to 1899, in the case of Winston against United States, it has commented upon our society's aversion to mandatory sentence of death.

Fifty years after Winston case, the Court underscored the marked transformation in our attitudes toward mandatory sentences and I quote from the case of Williams against New York, "The belief no longer prevails that every offense in a like legal category calls for an identical punishment without regard to the past life and habits of a particular offender.