Enmund v. Florida: Facts, Decision, & Significance

Instructor: Natalie Boyd

Natalie is a teacher and holds an MA in English Education and is in progress on her PhD in psychology.

When is the death penalty not allowed? This lesson will examine the Supreme Court case ''Enmund v. Florida,'' including a discussion of the court decision and an exploration of the significance of this case.

The Case 

If you help someone commit a crime, how responsible are you? This is the question asked in the 1982 Supreme Court case Enmund v. Florida

The case centered around Earl Enmund. He was a getaway driver for two of his friends, who robbed a couple in their home. During the robbery, gunfire was exchanged, and one of Enmund's friends killed the couple. 

The two people actually committing the robbery, including the one who murdered the victims, were convicted of first-degree murder, which in Florida is a capital crime. But it wasn't just Enmund's friends: he, too, was convicted and sentenced to death.  

Decision 

Did Earl Enmund deserve the death penalty? He and his lawyers argued no. Enmund claimed he had no desire or intention of killing anyone. He had no way of knowing that his friends would end up committing murder when he agreed to be the getaway driver. So how could he be convicted if he didn't intend to and didn't in action kill anyone? 

Enmund's case was appealed all the way to the Supreme Court of the United States. There, his lawyers argued that the death penalty in his case violated the Eighth Amendment, which prevents cruel and unusual punishment, and the Fourteenth Amendment, which prevents citizens from having their life, liberty, or property taken away without cause and due process. 

The argument was simple: Enmund didn't intend to commit murder. Further, he didn't commit murder. As a result, the death penalty was an unusually cruel punishment and thus it violated the Eighth Amendment. In addition, because he didn't commit murder or intend to commit murder, the death penalty was illegally depriving him of his life. 

By a narrow margin, SCOTUS agreed that the death penalty was cruel and unusual punishment for Enmund because he did not intend to kill, nor did he kill or attempt to kill, anyone. Justice Byron White wrote the majority opinion. 

Justice William Brennan, Jr. joined the majority in the vote, and he wrote a separate opinion that argued the death penalty is always cruel and unusual punishment. 

Justice Sandra Day O'Connor, along with three other justices, dissented. They argued that SCOTUS overturning Enmund's sentence interfered with states' rights. 

Significance 

What did the decision mean for future cases? The first and most obvious impact that this test had was to limit the people who could be sentenced to death. Thanks to Enmund v. Florida, capital punishment is reserved for people who planned, actively attempted, or succeeded in killing someone. Accomplices like Enmund, who did not plan, attempt, or kill anyone, cannot be given the death penalty. 

In addition, Justice Brennan's concurring opinion has its own significance. Thanks to his two-sentence opinion, there is Supreme Court precedence to argue that capital punishment is unconstitutional. If Brennan's opinion is accepted, the death penalty violates the Eighth and Fourteenth Amendments and therefore violates the United States Constitution. While this isn't the only SCOTUS opinion that argues that capital punishment is unconstitutional (Brennan himself penned a longer dissenting opinion that argued the same thing in the case Gregg v. Georgia), it adds to the anti-capital punishment opinions. 

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