Enmund v. Florida

The court charged Enmund with and convicted him of two counts of first-degree murder and one count of robbery. Because Enmund received the death penalty, he appealed his sentence to the Florida Supreme Court, which upheld the lower court's decision. The Florida Supreme Court argued that because Enmund was an accomplice in an armed robbery when the murders took place and because Enmund was previously convicted of a felony involving at least the threat of violence, the death sentence suited the crime.

On 23 March 1983, the U.S. Supreme Court began hearing the case and considering whether states could apply the death penalty without violating the Eighth and Fourteenth Amendments to felons "who neither took life, attempted to take life, nor intended to take life." In the 5-4 decision, the Supreme Court majority contended that the Eighth Amendment ban on cruel and unusual punishment did not allow a capital punishment sentence in this case, because of previous Supreme Court decisions such as Weems v. United States (1910) where a man was sentenced to 15 years of hard labor for falsifying a public document and Coker v. Georgia (1977) where a man received the death penalty for raping a woman. With these Supreme Court decisions in the background, the majority also compared the sentences of other jurisdictions with Enmund's sentence and found that of the 36 jurisdictions only 8 permit the death penalty in similar cases. Furthermore, the Court considered jury verdicts for death sentences and the death row population and noticed that accomplices who did not participate in the murder accounted for only a small minority, demonstrating that the general population rejects the use of the death penalty for an accomplice such as Enmund, who do not plan or attempt to kill.

Given this foundation, the Court found that although Enmund's robbery conviction was indeed a serious offense that warranted a stiff penalty, it was not so atrocious that it warranted capital punishment. While the Court admitted that the death penalty can apply to robbers who commit murder in the process of robbing without violating the Constitution, it maintained that in order for it to apply to Enmund's case and ones like it, courts must demonstrate that Enmund's behavior directly led to the murder, thus making him responsible. By studying statistics of robberies in the United States, the Court concluded that murders occur in conjunction with robberies only less than one percent of the time and so it showed that as a robber alone Enmund should not have anticipated murder as a possible outcome. Therefore, the Supreme Court majority reversed the state supreme court's ruling, finding the death penalty in this case a violation of the Eighth and Fourteenth Amendments.