Woodson v. North Carolina (1976) is the U.S. Supreme Court case holding that North Carolina’s mandatory death penalty for individuals convicted of first-degree murder violated the Eighth Amendment. Find the full opinion here.
North Carolina state law required application of the death penalty for all individuals convicted of first-degree murder. Woodson was charged with first-degree murder as a result of his participation in an armed robbery at a convenience store, where the cashier was killed in the course of the robbery. Woodson pleaded not guilty, arguing that another defendant coerced him into participating, but the jury convicted him of first-degree murder. Woodson challenged his conviction on the grounds that North Carolina’s mandatory death penalty for first-degree murder violated the prohibition on cruel and unusual punishment by the Eighth Amendment, through the Fourteenth Amendment and the incorporation doctrine. The Supreme Court of North Carolina upheld his conviction, and Woodson appealed to the U.S. Supreme Court, who granted certiorari.
The Supreme Court, in a 5–4 decision written by Justice Stewart, ruled that North Carolina’s law violated the Eighth Amendment and remanded the case to redetermine Woodson’s sentence. The Court first described one of the Eighth Amendment’s purposes, citing Supreme Court precedent, as assuring the State’s power to punish is “exercised within the limits of civilized standards.” Here, although mandatory death penalties were common at the time the United States ratified the Eighth Amendment in the late 18th century, states have nearly ubiquitously abandoned the mandatory death penalty, as jurors and legislators found them exceedingly harsh. For this reason, North Carolina’s law “is a constitutionally impermissible departure from contemporary standards respecting imposition of the unique and irretrievable punishment of death.”
Next, the Court took issue with the fact that North Carolina’s law provided no standards to guide juries in their exercise of the power to determine life or death. The North Carolina legislator passed the mandatory death penalty law in response to a North Carolina Supreme Court case which removed jury discretion for death penalty cases. But the U.S. Supreme Court rejected the State’s interpretation of that case as removing juries sentencing power and creating a mandatory death penalty, and instead ruled that a state must provide some standards to juries when they determine who shall live and who shall die. Lastly, the Court interpreted the “respect for human dignity underlying the Eighth Amendment'' to require individualized considerations of the offense and offender. It thus concluded that the North Carolina law is unconstitutional as it “impermissibly treats all persons convicted of a designated offense not as uniquely individual human beings, but as members of a faceless, undifferentiated mass to be subjected to the blind infliction of the death penalty.”
[Last updated in April of 2021 by the Wex Definitions Team]