People v. LaValle
People v. LaValle, 3 N.Y.3d 88 (2004), was a landmark decision by the New York Court of Appeals, the highest court in the U.S. state of New York, in which the court ruled that the state's death penalty statute was unconstitutional because of the statute's direction on how the jury was to be instructed in case of deadlock. New York has since been without the death penalty, as the law has not been amended.
Felony murder and the death penalty in the United States
Faced with the objective evidence suggesting that legislatures and sentencing juries did not uniformly reject the death penalty for "all" defendants convicted of felony murder, the Court had to limit the death penalty to a discrete and narrow category of felony murder defendants based on its estimation of which category would best effectuate the goals of retribution and deterrence. The "Enmund" Court stressed that the propriety of the death penalty must be measured in light of Enmund's "own" conduct. The "Tison" Court added that historically, the individualized determination incorporates an assessment of the mental state with which the defendant commits a crime, because a more culpable mental state merits a more severe punishment. In "Woodson v. North Carolina", the Court had struck down a mandatory death penalty statute because it failed to provide for individualized consideration at sentencing. The rule fashioned by "Enmund" and "Tison" accommodated this concern by ensuring that only felony murder defendants who had a sufficiently culpable mental state received the death penalty.