Woodson v. North Carolina

Written By Kellie Slappey

In medieval England, English Common Law ruled that death was the penalty for serious crimes.  This rule was enforced in the American colonies. By the time the Eighth Amendment was passed in 1791, the death penalty was the mandatory punishment for murder in all states.

By the 1800s, problems with the mandatory death sentence had begun to arise in the legal system. When the defendant was accused of murder the jury only had two options: convict the defendant of murder where the penalty was death or acquit the defendant and let him go. There was no means to express that the defendant should be punished but not executed.

North Carolina adopted reforms to the mandatory death sentence in 1893, and the crime of murder was divided into two degrees, with only first-degree murder being punishable by death. First-degree murder as currently defined in the North Carolina General Statues is, “any other kind of willful, deliberate, and premeditated killing.”

Although these reforms helped to ease the tension some juries still refused to convict defendants of first-degree murder because that crime carried a mandatory death penalty.

In 1974, James Woodson was found guilty of first-degree murder in North Carolina and was therefore automatically sentenced to death. Woodson appealed his death sentence, arguing that it was cruel and unusual punishment under the Eighth Amendment. Woodson challenged North Carolina’s mandatory death sentence but the Supreme Court of North Carolina upheld the law.

The U.S. Supreme Court agreed to review the case and on July 2, 1976, a 5-4 majority voted to over turn the North Carolina Supreme Court ruling. Justice Potter Stewart wrote the majority opinion for the U.S. Supreme Court decision, with Justices Brennan, Marshall, Powell, and Stevens joining in. Justice White wrote the dissenting opinion and Justices Burger, Blackman, and Rehnquist joined him in dissent.

The majority opinion listed three problems with the North Carolina law. First, the law did not meet contemporary standards of capital punishment; mandatory death sentences had been consistently rejected by the public. Second, the law provided no standards or criteria to act as a guide to juries in determining which first-degree murderers would live and die. Third, the law failed to allow juries to consider the character and record of the defendant before inflicting a death sentence. The Court noted that “the fundamental respect for humanity” underlying the Eighth Amendment required such considerations.

The Court took the case one step further and applied the criteria, which had been written in the case of Gregg v. Georgia, a case that was decided the same day as Woodson.  On July 2, 1976, the U.S. Supreme Court ruled on five death penalty cases. In addition to Gregg and Woodson, there was Jurek v. Texas, Proffitt v. Florida, and Roberts v. Louisiana. The Court established a two-prong criteria that the above death penalty cases and state legislatures must follow to craft a constitutional capital sentencing plan.

First, the system must provide objective criteria to direct and limit the death sentencing discretion. The objectiveness of these criteria must in turn be ensured by appellate review of all death sentences. Second, the scheme must allow the sentencer (whether judge or jury) to take into account the character and record of an individual defendant.

In applying this criteria, the U.S. Supreme Court justices found that North Carolina’s sentencing scheme did not pass the constitutional tests and that the state’s mandatory death sentence statute violated the Eighth and Fourteenth Amendments.