Enmund v. Florida - Implications Of Decision

Although the Supreme Court majority decided to overturn the lower courts' rulings, its decision did not constitute the final say in the execution of accomplice felons who did not attempt or intend to kill the victim in crimes that resulted in murder. The Court never overruled this decision, but it reached more stringent decisions for similar cases afterwards, reducing the role intent plays. For example, in 1995 the Court denied a man a stay of execution, even though the state admitted that he did not participate in the killing of the victim, whom he helped kidnap in Jacobs v. Scott.

The question before us is not the proportionality of death as a penalty for murder, but rather the validity of capital punishment for Enmund's own conduct. The focus must be on his accountability, not on those who committed the robbery and shot the victims, for we insist on `individualized consideration as a constitutional requirement in imposing the death sentence.'