Woodson v. North Carolina 1976
Woodson v. North Carolina 1976
Petitioners: James Tyrone Woodson and Luby Waxton
Respondent: State of North Carolina
Petitioners' Claim: That North Carolina's automatic death penalty for first degree murder violated the Eighth Amendment.
Chief Lawyer for Petitioners: Anthony G. Amsterdam
Chief Lawyer for Respondent: Sidney S. Eagles, Jr., Special Deputy Attorney General of North Carolina
Justices Dissenting: Harry A. Blackmun, Warren E. Burger, William H. Rehnquist, Byron R. White
Date of Decision: July 2, 1976
Decision: North Carolina's automatic death penalty was cruel and unusual punishment under the Eighth Amendment.
Significance: Woodson said death penalty laws must let juries choose between death and imprisonment. To make that decision, juries must consider the defendant's character, his prior criminal record, and the circumstances of the murder he committed.
Using the death penalty, governments kill people as punishment for crime. In the United States, most states allow the death penalty for first degree murder. Before 1972, most states allowed juries to decide death penalty cases with no guidance. Juries had total control to choose life or death for defendants who committed murder.
The Eighth Amendment prevents the government from using cruel and unusual punishments. In Furman v. Georgia (1972), the U.S. Supreme Court said death penalty laws that give juries total control are cruel and unusual under the Eighth Amendment. Many states, including North Carolina, changed their laws to take control away from juries. Under the new laws, defendants who were convicted of first degree murder automatically got the death penalty. In Woodson v. North Carolina, the question was whether these new laws were cruel and unusual.
Killing for Cash
James Tyrone Woodson and three other men in North Carolina had discussed robbing a convenience food store. On June 3, 1974, Woodson had been drinking alcohol in his trailer. At 9:30 p.m., Luby Waxton and Leonard Tucker arrived at Woodson's trailer. Waxton hit Woodson in the face and threatened to kill him if he did not join the robbery.
Woodson got into the car and the three men drove to Waxton's trailer, where they met Johnnie Lee Carroll. Waxton got a handgun, Tucker gave Woodson a rifle, and the four men drove to a convenience food store in one car. Tucker and Waxton entered the store while Carroll and Woodson stayed in the car as lookouts.
Inside the store, Tucker bought a pack of cigarettes. Waxton also asked the clerk for cigarettes. When she handed them over, Waxton shot her at point blank range. Waxton then removed money from the cash register and gave it to Tucker, who rushed back to the parking lot. From outside, Tucker heard another shot and then saw Waxton appear holding a wad of money. The four men drove away together.
As it turned out, the clerk died and a customer was seriously wounded. This made it a case of first degree murder. Tucker and Carroll pled guilty to crimes lesser than murder in exchange for testifying for the prosecution at Woodson and Waxton's trial. At trial, Waxton claimed that Tucker, not he, had shot the clerk and customer. Woodson, who was forced to go along that night and sat in the car during the robbery, refused to admit to any wrongdoing.
The jury found both Woodson and Waxton guilty of first degree murder. Under North Carolina's new law, they automatically got the death penalty. The judge and jury had no choice. Woodson and Waxton appealed their death sentences. They argued that the death penalty is cruel and unusual punishment under the Eighth Amendment. The U.S. Supreme Court agreed to review their case.
Automatic Death Penalty Unconstitutional
With a 5–4 decision, the Supreme Court reversed Woodson and Waxton's death sentences. Writing for the Court, Justice Potter Stewart first decided that the death penalty is not cruel and unusual punishment in all cases. When a criminal commits first degree murder, the death penalty makes the punishment fit the crime.
The Court decided, however, that automatic death penalties are cruel and unusual punishment. Stewart said punishment is cruel and unusual when it offends America's standards of decency. To determine these standards, Justice Stewart analyzed the history of the death penalty.
When the United States was born in 1776, many states had automatic death penalties for crimes such as murder, rape, and robbery. Juries, however, thought automatic death was too serious for certain crimes. This led most states to change their death penalty laws to give juries the choice between death and imprisonment. Stewart said this meant automatic death penalties offended American society.
CRUEL AND UNUSUAL PUNISHMENT
T he Eighth Amendment of the U.S. Constitution prevents the government from using cruel and unusual punishment. Most people agree that torture and other barbaric punishments are cruel and unusual. Does this mean the death penalty is cruel and unusual?
To answer this question, the Supreme Court uses the test from a non-death penalty case. In Trop v. Dulles (1958), Albert L. Trop lost his U.S. citizenship after deserting the U.S. army during World War II. The U.S. Supreme Court decided that taking away Trop's citizenship was cruel and unusual punishment under the Eighth Amendment. To decide what is cruel and unusual, the Court said it must consider American standards of decency as the country grows and matures.
In Woodson, the question was whether the death penalty is indecent in American society. The Court decided that when a criminal commits murder, the death penalty is not indecent. The death penalty cannot, however, be automatic. The law must allow juries to decide whether each criminal should live or die.
In Furman v. Georgia, the U.S. Supreme Court struck down laws giving juries too much control over the death penalty. But Stewart said automatic death penalties did not solve the problem. Instead, juries needed to decide the death penalty in each case based on the defendant's character and criminal record and the circumstances of his crime. Only such individual consideration would respect the humanity of each defendant. Justice Stewart said the Eighth Amendment required such respect in a civilized society.
After Furman outlawed the death penalty in 1972, Woodson and other cases decided on July 2, 1976 made it legal again. From 1976 through 1999, 598 people were executed in the United States. Protesters still say the death penalty is cruel and unusual punishment in any case. Supporters say people who commit murder deserve to die. Under Woodson, juries deciding death penalty cases must be guided by the defendant's character and background and the circumstances of his murder.
Suggestions for further reading
Almonte, Paul. Capital Punishment. New York: Crestwood House, 1991.
Gottfried, Ted. Capital Punishment: The Death Penalty Debate. Enslow Publishers, Inc., 1997.
Henson, Burt M., and Ross R. Olney. Furman v. Georgia: The Death Penalty and the Constitution. New York: Franklin Watts, Inc., 1996.
Herda, D.J. Furman v. Georgia: The Death Penalty Case. Enslow Publishers, Inc., 1994.
Mikula, Mark, and L. Mpho Mabunda, eds. Great American Court Cases. Vol. II. Detroit: The Gale Group, 1999.
Nardo, Don. Death Penalty. Lucent Books, 1992.
O'Sullivan, Carol. The Death Penalty: Identifying Propaganda Techniques. San Diego: Greenhaven Press, 1989.
Steins, Richard. The Death Penalty: Is It Justice? Twenty First Century Books, 1995.
Tushnet, Mark. The Death Penalty. New York: Facts on File, 1994.
Wawrose, Susan C. The Death Penalty: Seeking Justice in a Civilized Society. Millbrook Press, 2000.
Winters, Paul A., ed. The Death Penalty: Opposing Viewpoints. San Diego: Greenhaven Press, 1997.
Wolf, Robert V. Capital Punishment. Philadelphia: Chelsea House Publishers, 1997.