first-degree felony murder

Ronald Harmelin was convicted in Michigan state court of possessing 672 grams of cocaine. Michigan law imposed a mandatory sentence of life imprisonment without possibility of parole for that quantity of the drug. Harmelin had no prior felony convictions. The Michigan Court of Appeals initially reversed the conviction because evidence supporting it had been obtained in violation of the Michigan Constitution. On petition for rehearing, the Court of Appeals vacated its prior decision and affirmed the sentence. The Michigan Supreme Court denied leave to appeal. The United States Supreme Court granted certiorari. The quantity of cocaine at issue had a potential yield of between 32,500 and 65,000 doses. The sentencing court imposed the mandatory term without considering any individualized circumstances of the offense or the offender. Harmelin challenged the sentence on Eighth Amendment grounds, arguing both that it was grossly disproportionate to the crime and that the mandatory nature of the penalty was unconstitutional.

James Tyrone Woodson and Luby Waxton were convicted of first-degree murder following their participation in an armed robbery of a convenience food store on June 3, 1974, during which the cashier was killed and a customer was seriously wounded. There were four participants in the robbery: Woodson, Waxton, Leonard Tucker, and Johnnie Lee Carroll. Tucker and Carroll testified for the prosecution after pleading guilty to lesser offenses, while the petitioners testified in their own defense. The prosecution established that the men had discussed the robbery for some time. On the day of the crime, Waxton struck Woodson to sober him up after heavy drinking, and the group armed themselves before proceeding to the store. Tucker and Waxton entered the store, where Waxton shot the cashier at point-blank range and took the money tray, with a second shot fired before they fled. The petitioners' testimony largely agreed with this account except that Waxton claimed Tucker had done the shooting. The petitioners were found guilty on all charges and, as required by North Carolina's mandatory death penalty statute for first-degree murder, were sentenced to death. The statute had been enacted after the North Carolina Supreme Court in State v. Waddell severed the discretionary provision from the prior law in response to Furman v. Georgia. The North Carolina Supreme Court affirmed the convictions and death sentences in State v. Woodson, 287 N. C. 578, 215 S. E. 2d 607 (1975). The Supreme Court of the United States granted certiorari to consider whether the imposition of the death penalties comported with the Eighth and Fourteenth Amendments.

Ehrlich Anthony Coker was serving consecutive life sentences for murder, rape, kidnapping, and aggravated assault when he escaped from the Ware Correctional Institution near Waycross, Georgia, on September 2, 1974. Later that night, Coker entered the home of Allen and Elnita Carver through an unlocked kitchen door. He tied up Mr. Carver in the bathroom, took a knife from the kitchen along with money and car keys, raped the sixteen-year-old Mrs. Carver, and abducted her in the family car while threatening her husband. Coker was soon apprehended by police after the abduction. He faced charges of escape, armed robbery, motor vehicle theft, kidnapping, and rape in the Superior Court of Cobb County, Georgia. Following a determination that he was competent to stand trial, a jury convicted Coker on all counts after rejecting his plea of insanity. At the sentencing hearing, the jury found two aggravating circumstances and imposed the death penalty for the rape conviction. The Georgia Supreme Court affirmed Coker's convictions and the death sentence imposed for rape. The United States Supreme Court granted a writ of certiorari to consider whether the death penalty for rape of an adult woman violates the Eighth Amendment.