Friday, November 15, 2013

Godfrey v. Georgia case brief

Godfrey v. Georgia case brief summary
446 U.S. 420 (1980)


CASE SYNOPSIS
Defendant was convicted of murder and was sentenced to death. The Supreme Court of Georgia affirmed the death sentence. Defendant appealed the death sentence.

CASE FACTS
After an argument with his wife, defendant killed her and his mother-in-law with a shotgun through a window without their having seen him. Defendant immediately turned himself in to the police and confessed to the crime. Defendant was convicted of murder and was sentenced to death pursuant to O.C.G.A. § 27-2534.1(b)(7) (1978). To have been sentenced to death under § 27-2534.1(b)(7), the murder had to be "outrageously or wantonly vile, horrible, and inhuman."

DISCUSSION

  • The Court reversed the death sentence and remanded the action because there was no showing that the murder was "outrageously or wantonly vile, horrible, and inhuman" due to the quick deaths of the victims and the lack of torture. 
  • As a result, the sentence appeared to have been arbitrarily and capriciously imposed because there was no showing that the jury was restrained in its discretion, and there were no aggravating circumstances.

CONCLUSION
The Court reversed defendant's death sentence and remanded the action.


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