Enmund v. Florida
Citation and Court
458 U.S. 782 (1982) — Supreme Court of the United States
Facts
Enmund drove the getaway car while his accomplices committed robbery and killed two people. He was not present at the killings and did not kill, attempt to kill, or intend that anyone be killed. Under Florida’s felony murder rule, he was convicted of first-degree murder and sentenced to death.
Issue
Whether the Eighth Amendment’s prohibition on cruel and unusual punishment permits imposing the death penalty on a felony murder defendant who did not kill, attempt to kill, or intend that anyone be killed.
Holding
No; the Eighth Amendment prohibits imposing the death penalty on a defendant who participated in a robbery but did not kill, attempt to kill, or intend that a killing take place.
Rule / Doctrine
The death penalty must be proportional to the defendant’s individual culpability. A defendant who is a minor participant in a felony and does not take life, attempt to take life, or intend that life be taken lacks the level of moral culpability that would justify the ultimate penalty. The felony murder rule cannot supply the requisite intent for capital punishment purposes.
Significance
A leading Eighth Amendment proportionality case for capital felony murder. Subsequently clarified in Tison v. Arizona (1987), which held that major participation in a felony combined with reckless indifference to human life could support the death penalty even without a specific intent to kill.