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Keywords

appealfelonyaggravating circumstancescapital punishment

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Coker v. Georgia, 433 U.S. 584, 97 S.Ct. 2861, 53 L.Ed.2d 982

Facts

Ehrlich Anthony Coker, while serving sentences for previous violent crimes, escaped from a Georgia prison and committed armed robbery and rape against Mrs. Carver. He was convicted of multiple offenses, including rape, and sentenced to death based on aggravating circumstances related to his prior convictions and the commission of the crime during another felony. The Georgia Supreme Court upheld the conviction and sentence, leading to the appeal to the U.S. Supreme Court.

While serving various sentences for murder, rape, kidnaping, and aggravated assault, petitioner escaped from a Georgia prison and, in the course of committing an armed robbery and other offenses, raped an adult woman.

Issue

Is the imposition of the death penalty for the crime of rape of an adult woman a violation of the Eighth Amendment's prohibition against cruel and unusual punishment?

The Eighth Amendment bars not only those punishments that are ‘barbaric’ but also those that are ‘excessive’ in relation to the crime committed.

Rule

The Eighth Amendment bars not only barbaric punishments but also those that are excessive in relation to the crime committed, meaning a punishment is excessive if it does not contribute to acceptable goals of punishment or is grossly out of proportion to the severity of the crime.

A punishment is ‘excessive’ and unconstitutional if it (1) makes no measurable contribution to acceptable goals of punishment and hence is nothing more than the purposeless and needless imposition of pain and suffering; or (2) is grossly out of proportion to the severity of the crime.

Analysis

The Court analyzed the application of the death penalty in the context of societal standards and legislative attitudes towards capital punishment for rape. It noted that Georgia was the only state allowing the death penalty for the rape of an adult woman and that juries had not imposed the death penalty in the vast majority of rape cases. The Court concluded that the death penalty for rape does not meet the constitutional standards of proportionality and is therefore excessive.

We have concluded that a sentence of death is grossly disproportionate and excessive punishment for the crime of rape and is therefore forbidden by the Eighth Amendment as cruel and unusual punishment.

Conclusion

The U.S. Supreme Court reversed the Georgia Supreme Court's decision, ruling that the death penalty for the crime of rape of an adult woman is unconstitutional under the Eighth Amendment. The case was remanded for further proceedings.

The judgment of the Georgia Supreme Court upholding the death sentence is reversed, and the case is remanded to that court for further proceedings not inconsistent with this opinion.

Who won?

Coker prevailed in the case as the U.S. Supreme Court ruled in his favor, determining that the death penalty for rape is unconstitutional. The Court's reasoning was based on the disproportionate nature of the punishment compared to the crime.

Mr. Justice WHITE, joined by Mr. Justice STEWART, Mr. Justice BLACKMUN, and Mr. Justice STEVENS, concluded that the sentence of death for the crime of rape is grossly disproportionate and excessive punishment and is therefore forbidden by the Eighth Amendment as cruel and unusual punishment.

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