Fowler v. North Carolina (1975)
- Docket
- 73-7031
- Decided
- 1975-01-01
Summary
Question: Is a mandatory death sentence under state law a violation of the Eighth Amendment's Cruel and Unusual Punishment provision as applied to the states under liberty protected by due process of the Fourteenth Amendment? Conclusion: The Court deferred action in Fowler's case until it resolved the question of mandatory death sentences in five cases heard and decided in the 1975 Term. One of these cases was Woodson v. North Carolina, 428 U.S. 280 (1976), which held that the mandatory imposition of the death sentence violated the Cruel and Unusual Punishment prohibition of the Eighth Amendment and the Due Process requirement of the Fourteenth Amendment. Following Woodson, the Court by memorandum vacated Fowler's mandatory death sentence and returned the case to the North Carolina for further proceedings. Fowler was resentenced to life in prison.