Thursday, January 31, 2013

Coker v. Georgia case brief

Coker v. Ga. case summary
33 U.S. 584

PROCEDURAL HISTORY: Defendant sought review of the judgment of the Georgia Supreme Court, which affirmed his conviction for rape and a jury-returned death sentence. The court granted defendant a writ of certiorari on the limited claim that the punishment of death for rape violates the Eighth Amendment.

FACTS:
-Defendant was convicted of rape and sentenced to death by a jury.
-The state supreme court affirmed both the conviction and sentence, and the court granted defendant's writ of certiorari for the limited purpose of determining whether a death sentence for a rape conviction violated the Eighth Amendment, which proscribed cruel and unusual punishments and which must be observed by states as well as the federal government.

HOLDING:
-After conducting an examination of recent death penalty cases that invoked the Eighth Amendment, as well as the trend of state legislatures to pass or repeal laws concerning death sentences for persons convicted of rape, the court held that a sentence of death was grossly disproportionate and excessive punishment for the crime of rape.

ANALYSIS:
It did not matter that the Georgia statute required the existence of an aggravating circumstance in order for the jury to return a death sentence. Imposition of the death penalty for rape cases was cruel and unusual punishment and violated the Eighth Amendment.

CONCLUSION: The judgment of the state supreme court upholding the death sentence was reversed, and the case was remanded for further proceedings not inconsistent with the court's opinion. ---
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