Coker v. Georgia
Coker v. Georgia is a significant U.S. Supreme Court case that addressed the constitutionality of capital punishment for the crime of rape. The case arose after Ehrlich Anthony Coker, already serving time for multiple serious offenses, escaped prison and committed a rape. Upon his conviction for this rape, Coker was sentenced to death, a penalty that raised substantial legal questions. In a landmark decision, the Supreme Court, by a 7-2 vote, reversed the death sentence, emphasizing that punishment should be proportionate to the crime committed. Justice Byron R. White argued that it was inappropriate for a rapist to receive a harsher penalty than a deliberate murderer, especially since Georgia was unique in allowing the death penalty for raping an adult woman. The ruling indicated a judicial inclination against capital punishment for crimes that do not involve intentional murder, reflecting evolving societal standards regarding justice and punishment. This case has profound implications for the legal landscape surrounding the death penalty and its application to non-homicidal offenses.
Coker v. Georgia
Date: June 29, 1977
Citation: 433 U.S. 584
Issues:Capital punishment; substantive due process
Significance: The Supreme Court held that capital punishment for the crime of rape is an excessive and disproportionate penalty and therefore contrary to the prohibition against cruel and unusual punishments in the Eighth and Fourteenth Amendments.
While serving sentences for murder, rape, and other crimes, Ehrlich Anthony Coker escaped from a Georgia prison. That same evening he raped a woman in her home and then forced the woman to leave with him. When apprehended, he was tried on charges of rape, armed robbery, and kidnapping. Using procedures that had been approved by the Supreme Court in Gregg v. Georgia (1976), the jury found Coker guilty of rape with aggravating circumstances and sentenced him to death.
By a 7-2 vote, the Court reversed the death sentence and remanded the case to the trial court for new sentencing. Writing for a plurality, Justice Byron R. White argued that the state could not sentence a defendant to a punishment disproportionate to the harm that he had inflicted on the victim. White also noted that Georgia did not apply the death penalty in cases of deliberate murder without aggravating circumstances, and he found that the disproportionality principle meant that a rapist should not be punished more severely than a deliberate murderer. Finally, observing that the Court’s precedents defined the term “cruel and unusual” according to the “evolving standards of decency that mark the progress of a maturing society,” White pointed to the fact that Georgia was the only state to authorize the death penalty for the rape of an adult woman.
The Coker decision suggested that the Court would probably not approve of capital punishment for any crime less than intentional murder. The majority of the justices have usually rejected the disproportionality principle in noncapital cases, as in Rummel v. Estelle (1980), but an important exception is Solem v. Helm (1983).
Bibliography
Acker, James R. "Proportionality: Offenses and Offenders." Questioning Capital Punishment: Law, Policy, and Practice. New York: Routledge, 2014. Print.
"Coker v. Georgia." Oyez. Chicago-Kent College of Law at Illinois Tech, n.d. Web. 7 Jan. 2016.
Foerster, Barrett J., and Michael Meltsner. Race, Rape, and Injustice: Documenting and Challenging Death Penalty Cases in the Civil Rights Era. Knoxville: U of Tennessee P, 2012. Print.
Latzer, Barry. Death Penalty Cases: Leading U.S. Supreme Court Cases on Capital Punishment. Burlington: Elsevier, 2011. Print.
Vollum, Scott. The Death Penalty: Constitutional Issues, Commentaries, and Case Briefs. 3rd ed. Abingdon: Routledge, 2015. Digital file.