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Woodson v. North Carolina


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428 U.S. 280 (1976), argued 31 Mar. 1976, decided 2 July 1976 by vote of 5 to 4; Stewart for the Court, Brennan and Marshall concurring, White, Burger, Blackmun, and Rehnquist in dissent. Woodson, an accomplice in a robbery/murder, had been convicted of first-degree murder. Under North Carolina law, he received a mandatory death sentence. Following Furman v. Georgia (1972), North Carolina had replaced its discretionary sentencing system with a mandatory death sentence for first-degree murder. This case, decided on the same day as Gregg v. Georgia (1976), reversed the lower court's approval of mandatory sentencing on Eighth Amendment grounds.

Justice Potter Stewart's opinion held that the constitutional proscription of cruel and unusual punishments required the state to exercise its power to punish within the limits of civilized standards. Stewart insisted that evolving standards of decency have moved away from mandatory sentencing and that most death penalty laws reenacted after Furman did not provide for automatic death sentences. Those that did treated people not as unique individuals but as part of a faceless and inhuman mass, in violation of the Eighth Amendment. Stewart also noted that, in light of evidence that juries will tailor the death penalty to individual circumstances, the North Carolina statute might encourage juries to find a defendant innocent only to avoid mandatory capital punishment. Such choices would necessarily be made without specific statutory guidance and would thus violate the requirements set out in Gregg. William J. Brennan and Thurgood Marshall concurred by reiterating their view that the death penalty violated the Eighth Amendment per se. The dissenters questioned the Court's capacity to determine that mandatory sentencing was less evenhanded than a system of statutory guides to discretionary sentencing.

Lief H. Carter

Subjects: Law.


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