Coker v. Georgia case brief, 433 U.S. 584 (1977)

Coker v. Georgia
433 U.S. 584 (1977)

FACTS
-D escaped from prison and entered the victim's house (husband and wife), robbed the husband and raped the wife.
-D was tried and under Georgia law, a jury sentenced the defendant to death under the charge of rape.

PROCEDURAL HISTORY
-The jury was presented with a Georgia statute for rape.

-Jury could consider whether 1. rape was committed by a person with a prior record of conviction for a capital felony;
2. that the rape was committed while the offender was engaged in the commission of another capital felony; or
3. the rape was outrageously or wantonly vile horrible or inhumane.
-The jury found that the D had about two previous rape convictions and a murder conviction and he was an escaped convict. Also, D committed the rape while in the process of committing robbery. As a result, the death penalty was rendered to the D.
-The defendant appeals and argues that this sentence was “cruel and unusual” under the Eighth Amendment of the Constitution.

ISSUE
Whether the crime of rape committed by a criminal with past serious criminal record can be punished by a death sentence?

HOLDING
No.

ANALYSIS
-Court ruled the death sentence was too excessive for the crime of rape.
-The court considered the statistics of how states were stepping away from death sentences in rape cases and used these statistics to back up its ruling.
-The court reasoned that death sentence in itself is not cruel and unusual, but this sentence in a rape case is too disproportionately excessive.
- “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.”
-In the current case, an adult woman was raped and even though it was a serious crime, but still it was not as serious as a murder. The death sentence was simply too harsh. Sentence reversed.

NOTES
Harmelin v. Michigan: Life sentence for large drug possession.
-Court overturned the previous ruling in Solem. Court said that legislators should be give the power to decide whether some crimes should be punished more severely than the others.
-The court said that the Eighth Amendment doe not require proportionality.
-Justice Scalia said that the court went ahead and ruled on death penalty in Coker v. Georgina, but the court will not extend this rule to the death penalty.

Link to case:  433 U.S. 584 (1977)