Running head: A CALL FOR JUSTICE 1

A Call for Justice: The Trials and Tribulations of Capital Punishment

Abigail D. Horner

Legal Studies Academy

First Colonial High School

Abstract

This paper reviews the background and history of capital punishment, as well as the current

issues and trends that can be seen in the United States. The author discusses the implementation

and arbitrariness between regions in the United States. The author also investigates both views

on capital punishment, and reasons with both sides. The author concludes by giving a possible

solution to the issue of the death penalty.

A Call for Justice: The Trials and Tribulations of Capital Punishment

“Capital Punishment is like amputating a diseased limb to protect the body. This… still

is, the official teaching of the Catholic Church. The only thing that has changed is whether it’s

prudent to amputate the limb in a specific situation" (St Thomas Aquinas, 2017). There are two

views on capital punishment, either for or against, and it is unlikely that any amount of

information or statistics will sway one’s viewpoint. Knowing what punishment best fits the

crime is at the heart of the argument against the death penalty. Those who support the death

penalty want to be positive the criminal is getting their “Just desserts,” but who is to say when

death is the necessary step? In the United States, the death penalty arbitrarily executes certain

groups in society by sentencing those to death who can not afford proper council, and it is

dependant on what state the criminal is in and the crime that has been committed.

The History of Capital Punishment

According to the Death Penalty Information Center (2019), capital punishment originated

in Babylon as far back as the Eighteenth Century B.C. Britain then adopted this trend, and in the

Tenth Century A.D., the main method of execution was hanging. Execution was outlawed in the

following century, but in the Sixteenth Century, King HenryVIII imposed executions again.

People would be executed for the most ludicrous of crimes by way of “...boiling, burning at the

stake, hanging, beheading, and drawing and quartering.” The British courts soon realized that

reform was needed because it was so barbaric, and in 1823, they began to do just that. When the

European colonists came over to America, they greatly influenced our use of the death penalty,

for they brought it over with them (Death Penalty Information Center, 2019).
A CALL FOR JUSTICE 4

Methods

The first imposement of the death penalty on American soil was in 1608, and it would not

be the last. In 1612, the Divine and Martial Laws were enacted, covering extreme as well as

minor crimes through the process of hanging (Death Penalty Information Center, 2019). In the

early history of America, hanging and burning alive were popular methods of execution. As the

population of America grew, so did the popularity of hanging. More than 200 years later, in

1890, hanging was abolished, and electrocution became the preferred method of execution. In

1924, lethal gas began to be used, but it was soon shown that both of these methods had

problems; lethal gas was being used in rooms that were too cold, and the gas instead stayed on

the ground, and in the case of electrocution, a man was shocked, but he did not die. Half a

decade later, the United States Supreme Court found that the state’s statutes on the death penalty

were arbitrary and stopped all executions. Four years later, all states changed their statutes and

executions began again. In 1982, lethal injection was first used, and it is now the most common

method of execution in the United States. Each of these methods have proven to be effective;

however, they all have had cases where the outcome was less than wanted (Ford, 2015).

Laws and Court Cases

The first case in which capital punishment was brought to the United States Supreme

Court was the case of ​Furman v. Georgia (​ 1972). The decision of this case changed the idea of

the constitutionality of capital punishment. William Furman went to the home of a Georgia

resident and robbed him. The victim woke up to Furman burglarizing his home, and on the way

out, Furman tripped and his gun went off, killing the resident. Furman was sentenced to death for

the murder, but he appealed up to the United States Supreme Court. The question brought to the
A CALL FOR JUSTICE 5

Supreme Court was whether or not the death penalty was considered cruel and unusual

punishment in this case under the Eighth and Fourteenth Amendments. In a 5-4 decision, the

judges found that in this case, it was considered cruel and unusual punishment, and two judges

believed capital punishment was cruel and unusual in any case (​Furman v. Georgia​, 1972).

Four years later, ​Gregg v. Georgia (​ 1976)​ ​was brought in front of the United States

Supreme Court, where the opposite of ​Furman v. Georgia ​was found. Similar to Furman, Gregg

had also murdered two people in the process of robbing them; however, it was found that his

situation did not violate the Eighth or Fourteenth Amendments.

The Supreme Court case that would change outcomes of many cases to come was ​Ring v.

Arizona​ (2002). Timothy Ring and two of his friends shot a man, and took his car, along with

thousands in cash. Ring was convicted of both armed robbery and murder, but he was sentenced

to death for only the one count of murder. This case called into question the interpretation of

aggravating factors that are determined by a judge and whether a jury should have the deciding

factor on whether or not aggravating factors are present under the Sixth Amendment. It was

found that this was in violation of the Sixth Amendment, and he was instead sentenced to life in

prison without possibility of parole (KOLD News, 2007). This case set a precedence to having a

jury decide whether they find aggravating factors to sentence a person to death (​Ring v. Arizona,

2002​).​

More recent cases have made huge strides toward closing the gap of arbitrariness in the

sentencing of offenders. In ​Atkins v. Virginia ​(2002), Daryl Atkins and a friend abducted a man

from the convenience store, then proceeded to rob him and kill him. Both men’s testimonies

were inconsistent with one another, and it was found that Atkins was mentally retarded. The
A CALL FOR JUSTICE 6

question was whether or not it was cruel and unusual punishment to sentence somebody to death

if they were not at a certain mental capacity, and the United States Supreme Court found that it

did violate the Sixth Amendment (​Atkins v. Virginia, 2​ 002).

Issues

There are many factors that influence a criminal’s sentencing, including whether or not

they have a mental illness, their age, and what crime was committed. However, other factors that

appear to have no correlation to the crime seem to influence their fate such as race, geography,

and the quality of their counsel. Supreme Court Justice Sandra Day O’Connor explained the

reasons as to why certain people may be at a disadvantage when it comes to whether or not they

are prone to commit crimes. O’Connor explains the sense behind sentencing by stating:

Evidence about the defendant’s background and character is relevant because of the

belief, long held by this society, that defendants who commit criminal acts that are

attributable to a disadvantaged background, or to emotional and mental problems, may be

less culpable than defendants that have no such excuse. The sentence imposed at the

penalty stage should reflect a reasoned moral response to the defendant’s background,

character, and crime.

O’Connor stated this after the decision of ​California v. Brown ​(1987) that one must consider all

factors, aggravating and mitigating, when sentencing a criminal to death, which does not mean to

take sympathy on the defendant, but to explore the backgrounds and possible reasonings.

The Cost of Killing

People believe that execution is cheaper than life imprisonment as once they are

executed, they no longer require the money to stay in a cell, but the opposite is true. This is
A CALL FOR JUSTICE 7

because there is a pre-trial to conclude there is a case for capital punishment, and a second trial if

the convicted is found guilty. There is also an appeals process that follows a sentence of death,

and the facilities that death row inmates stay at for typically ten years or more cost more than a

normal prison due to the fact that there is higher security in these special facilities (Henderson,

2005).

Some costs that apply to a death row case that are not required for regular cases are

longer trials, extended time for jury selection, extra lawyers and expert witnesses, and an inflated

price for jail (Death Penalty Information Center, 2019). Due to the fact that it costs millions of

dollars a year for this system, money is taken from programs that actively help the community.

There is less money to fund other trials, such as domestic violence, child abuse, and drugs, as

well as less human resources for “Crime prevention, mental health treatment, education and

rehabilitation, meaningful victims’ services, and drug treatment programs” (Amnesty

International).

Irreversibility

Between 1975 and 2005, eighty-seven people have been sentenced to death and then

freed when evidence was found on their innocence. There is no evidence of how many innocents

have been executed due to the fact that once someone has been executed, the case is technically

closed, and it is no longer looked into. Defenders are not able to look further into these cases

because they are overflowing with cases and have no time to continue the case (Henderson,

2005).

Due to the fact that cases are closed after a person is executed, the statistics of exonerees,

“For every ten people who have been executed… one person has been set free” (National
A CALL FOR JUSTICE 8

Coalition to Abolish the Death Penalty, 2019), could be a lot higher. There is no room for error

when sentencing someone to death because “You can release an innocent man from prison, but

you can’t release him from the grave” (Scott Langley). A study done between the years 1973

and 2004 have shown that 4.1% of defendants on death row are actually innocent, as opposed to

the previously believed 1.6%. It is still, and probably will always be, unclear as to how many

have actually been executed, but with the rate of error, as shown in the study, “you cannot

believe that we haven’t executed any innocent person – that would be wishful thinking” stated

Samuel Gross, a law professor at the University of Michigan. If not exonerated and not executed,

the innocent defendants are instead sent to life in prison, where they will likely die and be

forgotten (Pilkinton, 2014).

Ineffective

The reason capital punishment is legal is to punish the worst of the worst and to deter

people from engaging in criminal acts in the future. The implemenation of the death penalty

makes people think twice about committing crime, but there is no real evidence to prove that

having a sentence of the death penalty decreases crime since there are many other factors

(Henderson, 2005). Many times crimes are committed against family members, or someone the

suspect knew, which makes them isolated incidents with a specific reason, and the activity is

unlikely to occur again from that individual (Henderson, 2005). Murderers tend not to commit

crimes after being in prison as they have longer sentences and do not want to repeat the time they

spent there, and if they are sentenced to life, they do not have the option to commit the same

crimes again (Imbrogno, 2019). The idea that capital punishment deters people from committing

crimes is unfounded because if someone is going to commit murder, oftentimes, they do not
A CALL FOR JUSTICE 9

think about the consequences of their actions, and therefore, capital punishment is not a viable

deterrent (Henderson, 2005).

Arbitrariness

Since the beginning, the deciding and imposement of the death penalty have been less

than equal. Depending on what state the crime was committed in, the criminal may get life in

prison, or he be executed for the same or lesser crime. It has been more than thirty years since

the United States halted executions after ​Furman v. Georgia d​ ue to the arbitrariness of the

implications of the death penalty, yet nothing has changed since then, and the same issues persist

today (American Civil Liberties Union, n.d.).

Aileen Wuornos shot seven men before robbing them and taking their cars in 1989 and

1990. She would use the ruse of a prostitute to get into their cars, and when the victims were

unsuspecting, she would shoot them, drop them on the side of the road, and take their cars.

These crimes occurred in Florida, where the penal code states someone can be sentenced to death

if these factors are found: “The defendant murdered two or more victims, that the defendant

committed a murder for hire, or that the murder was intentionally committed in the course of a

kidnapping, burglary, robbery, aggravated rape or other statutorily specified felony” (Capital

Punishment in Context, nd.). Wuornos was convicted of seven murders committed in the course

of a robbery, which according to the Florida Penal Code states she should be sentenced to death,

and she was, even though she had mental issues (Capital Punishment in Context, n.d.).

Gerard John Schaefer, similarly, committed crimes in Florida where the Penal Code is the

same. He raped and mutilated between two and nine women from 1969 to 1972. He was only

convicted of two of the murders due to the fact that there was no concrete evidence he killed the
A CALL FOR JUSTICE 10

others, but he was suspected to have killed dozens more. Schaefer was sentenced to two

consecutive life terms (Murderpedia). The Florida Penal Code states that if “The defendant

murdered two or more victims” or if it was “intentionally committed in the course of…

aggravated rape” (Capital Punishment in Context, n.d.), then they shall be sentenced to death

(Murderpedia). Shaefer fits both of these descriptions, yet he was only sentenced to two life

terms, while Aileen Wuornos was sentenced to death.

All this means is that it is pure luck whether one lives or dies. The courts take into

consideration factors that should not be taken into account, and that are sometimes taken into

account for some trials, but not for others. The stakes at hand are higher than with many

decisions that have to be made, which means the time and effort needs to be higher as well.

Crime. ​The death penalty was created to punish the most inhumane and cruel crimes,

but the Violent Crime Control Act, enacted in 1994, allowed over fifty crimes that resulted in the

death of a person, as well as additional crimes that did not include actions resulting in a death, to

be grounds for execution (Henderson, 2005). Prosecutors tend to try for the death penalty when

the victim is white and the defendant is black, rather than when the victim is black and the

defendant is white. (Amnesty International, 2019). This is another way the death penalty is

unfair and unjust to people of a minority race.

Counsel. ​ People who are able to hire better counsel are less likely to be sentenced to

death. According to Supreme Court Justice William Douglas, "One searches our chronicles in

vain for the execution of any member of the affluent strata of this society" (1972), and that still

rings true 47 years later. Someone who is unable to hire their own attorney and receives a court

appointed counsel will have a 1.87 times more likely chance to be sentenced to death than
A CALL FOR JUSTICE 11

someone who hired their own counsel. Court appointed counsel tends to be less competent than

those hired, having cases of counsel coming to court while under the influence, falling asleep

while court was in session, or having no defense when being offered sentencing (Phillips, 2009).

Views

The two main arguments for or against capital punishment is deterrence and retribution.

Deterrence is the belief that an idea will cause unease in an idea due to the consequences, and

retribution is “Punishment imposed (as on a convicted criminal) for purposes of repayment or

revenge for the wrong committed (Mirriam-Webster, 2019).

Deterrence

In the argument for capital punishment, many believe that the option of the death penalty

creates a second thought when someone thinks about committing a crime; however, abolitionists

believe that there is no conclusive evidence to prove this. The reason being there are other

factors involved in crime rate and the death penalty, and there is no obvious correlation.

Thorsten Sellin, a sociologist, did a study in the United States where he observed the

states that had the death penalty, and those who did not, and he looked at the murder rates. He

also looked at states that used to have the death penalty, and he studied the murder rates before

and after it was abolished; he saw no correlation between the two. Hans Zeisel, similarly, did a

study that looked at homicide rates between states that did or did not have the death penalty, and

he did not see an increase in those states that abolished the death penalty. James Q. Wilson, a

political scientist, argued that these studies are void due to the fact that you can not compare

between states as they are different in laws, views, and geography (Henderson, 2005).
A CALL FOR JUSTICE 12

The United States has the highest murder rate in the world, particularly in the south

where the rates of execution are higher, which nullifies the idea that executions are a deterrent to

crime. The trend since 1990, and still rings true today, is that murder rates tend to be higher in

states that have the death penalty than those who do not (Death Penalty Information Center,

2019). ​Retribution

The Bible states, “Whosoever sheddeth a man’s blood, so shall his blood be shed”

(Genesis 9:6), which backs up the belief of an “Eye for an eye.” Polly Klass was a 12-year-old

girl who was kidnapped and murdered by Richard Allen Davis, and when asked to comment,

Polly’s father, Marc Klass stated, “When Richard Allen Davis gets executed for killing my

12-year-old daughter Polly, after kidnapping her from a slumber party in 1993, I’ll be there to

watch him go down. I’d like my eyes to be the last thing he sees, just as his eyes were the last

thing my child saw.” The families of those who were murdered want the murderers to be

punished for their actions, and many want the punishment to be the same as the crime they

committed. On the other hand, the Bible can also be used against the death penalty. Jesus Christ

believed in “Forgiveness and redemption” and this is shown throughout Christianity. Pope John

Paul II also denounced capital punishment in 1995 (Henderson, 2005).

Regional Differences

Twenty-one states have abolished the death penalty, including Alaska, Connecticut,

Deleware, Hawaii, Illinois, Iowa, Maine, Maryland, Massachusets, Michigan, Minnesota, New

Hampshire, New Jersey, New Mexico, New York, North Dakota, Rhode Island, Vermont,

Washington, Wisconsin, and West Virginia. The twenty-five states that still use the death

penalty as a form of punishment are Alabama, Arkansas, Arizona, Florida, Georgia, Idaho,
A CALL FOR JUSTICE 13

Indiana, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, Nevada,

North Carolina, Oklahoma, Ohio, South Carolina, South Dakota, Tennessee, Texas, Utah,

Virginia, and Wyoming; California, Colorado, Oregon, and Pennsylvania have governnor

imposed moratoriums.

Most of the overarching laws for the states that still have the death penalty are similar,

but some factors are considered or exluded depending on the state. In Alabama, the judge can

override a jury’s recommendation of life, and sentence death instead, which occurs in 90% of

cases. Many of the differences between states include whether “Treason, aggravated kidnapping,

drug trafficking, aircraft hijacking, or aggravated assault” constitutes the maximum sentencing

given where seven of the twenty-five states qualify treason, five qualify aggravated kidnapping,

and two qualify drug trafficking and aircraft hijacking. In Arkansas, Florida, and Utah, there is

no minimum age for whom can be sentenced to death, even though the case of ​Roper v. Simmons

(2005) decided that it is considered cruel and unusual punishment to execute a minor (FindLaw,

2019).

In Texas, capital punishment may be considered if the situation includes: “A police

officer or fireman killed while on duty; the murder occurred while the defendant was

committing” another felonly, “murder "for hire"; the murder occurred during the course of an

actual or attempted prison break; multiple murders occurred; and the victim was younger than

ten year old” (FindLaw, 2019). A partial reason for this is due to the fact that the appellate judges

in Texas are elected as opposed to appointed. This results in the judges ruling according to the

public instead of the law. The Fifth Circuit of the Federal Court of Appeals, which includes the
A CALL FOR JUSTICE 14

state of Texas, is pro-death penalty, which causes them to need few aggravating factors when

deciding, and provide few limitations to the factors considered (Walpin, 2019).

If you have committed first degree murder in Louisiana, you will automatically receive

the death penalty unless a judge states otherwise (Hager, 2019). This follows the belief of the

Fifth Circuit of the Federal Court of Appeals, which also includes Louisiana, and would prefer to

execute an offender rather than leave them in prison.

According to a legal representative, in Virginia, there are sentencing guidelines that each

judge has, and they sentence criminals according to their crime and what the guidelines state.

This is to limit the arbitrariness of sentencing in general, but vastly helps to limit arbitrariness in

the sentencing of the death penalty. The sentencing is also determined by other factors such as

whether or not it was their first crime, if they were apologetic, or the circumstances that were

surrounding the crime (Imbrogno, 2019).

Possible Solutions

Many supporters of the death penalty believe that criminals who are sentenced to life in

prison never actually serve that time; instead, it is believed that criminals on average serve 20

years. People want to feel secure in the idea that the offenders are never able to commit a crime

again, and that execution is the only surefire way to ensure this. A way to fix this is to give

offenders multiple life sentences without the possibility of parole and have them work jobs in the

prison where the money they make will be given to the families of the victims. This does not

bring the victims back, but the families are given a sort of retribution in the form of money

(Henderson, 2005).

Conclusion
A CALL FOR JUSTICE 15

The death penalty causes a tremendous debate among our society today. Due to its

inequitable ways of targeting people unfairly and unjustly, this debate is not going away any time

soon. There are many factors to consider when deciding whether one lives or dies, but the main

one should be if the punishment matches the crime. The judicial system needs to consider other

options that are more humane or more equal because, “An eye for an eye only ends up making

the whole world blind” (Mahatma Gandhi, n.d.). If the United States continues on the path of

retribution and revenge, the only outcome is more pain, more pain for those who are executed,

and more pain for the families who get no true retribution from such a punishment.
A CALL FOR JUSTICE 16

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A CALL FOR JUSTICE 21

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