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?

Conclusion

In a 5-to-4 decision, the Court held that the North Carolina law was unconstitutional. The Court found three problems with the law: First, the law "depart[ed] markedly from contemporary standards" concerning death sentences. The historical record indicated that the public had rejected mandatory death sentences. Second, the law provided no standards to guide juries in their exercise of "the power to determine which first-degree murderers shall live and which shall die." Third, the statute failed to allow consideration of the character and record of individual defendants before inflicting the death penalty. The Court noted that "the fundamental respect for humanity" underlying the Eighth Amendment required such considerations.