Godfrey v. Georgia – Case Brief Summary
Summary of Godfrey v. Georgia, 446 U.S. 420, 100 S. Ct. 1759, 64 L. Ed. 2d 398 (1980).
Godfrey (D) and his wife had a heated argument one evening after he had consumed several cans of beer. Godfrey threatened her with a knife and damaged her clothing. His wife announced that she was leaving him and secured a warrant charging him with aggravated assault.
Godfrey’s wife filed for divorce and after a heated argument over the telephone he carried his shotgun to his mother-in-law’s home. The defendant fatally shot his wife, struck his fleeing daughter, reloaded the weapon, and fatally shot his mother-in-law. He then called the sheriff, surrendered, and confessed. The defendant pled not guilty by reason of insanity but was convicted of all counts.
Under Georgia law, a person convicted of murder may be sentenced to death if it is found beyond a reasonable doubt that the offense “was outrageously or wantonly vile, horrible or inhuman in that it involved torture, depravity of mind, or an aggravated battery to the victim.” The jury found that Godfrey’s acts were outrageously or wantonly vile, horrible, and human and Godfrey was sentenced to death. The Georgia Supreme Court affirmed and the United States Supreme Court granted cert.
Is a death sentence imposed on the grounds that a murder was “outrageously or wantonly vile, horrible and inhuman” arbitrary and capricious?
Yes. A death sentence imposed on the grounds that a murder was “outrageously or wantonly vile, horrible, and inhuman” is arbitrary and capricious and therefore unconstitutional for violation of the Eighth and Fourteenth Amendments to the United States Constitution.
Under these facts, Godfrey’s crimes cannot be said to have reflected a consciousness materially more depraved than that of any other person guilty of murder. His victims were killed instantly. They were members of his family who were causing him extreme emotional trauma. Shortly after the killings, the defendant turned himself in and confessed. There is no way to distinguish this case from the many cases in which the death penalty was not imposed. In affirming the death sentence, the Georgia Supreme Court adopted such a broad and vague construction of the statute as to violate the Eighth and Fourteenth Amendments to the United States Constitution.
Reversed and remanded for further proceedings.
The death penalty is in all circumstances cruel and unusual punishment. The construction of this provision at issue in this case is unconstitutionally vague. The death penalty cannot be imposed in a way that will eliminate the risk that it will be imposed in an arbitrary and capricious manner. The task of eliminating arbitrariness in the infliction of capital punishment is proving to be one which our system is unable to perform.
The defendant admitted to committing a hideous crime and the majority is sadly mistaken in its course.
Godfrey murdered his wife and mother in law in front of his daughter in a cold-blooded fashion and struck his daughter with the shotgun. He also took the time after the first murder to reload the shotgun, go into the house, and shoot his mother in law. Godfrey used a weapon known for its disfiguring effects on human targets. I would affirm.
See Lassiter v. Department of Social Services for a law school civil procedure case brief in which the United States Supreme Court held that the Fourteenth Amendment does not require appointment of counsel for indigents in all parental status termination proceedings.