Eddie Lee Mays
Mays would become the last person to be executed by "Old Sparky", New York State's electric chair at Sing Sing prison. The State Electrician was Dow Hover. The electric chair had been the sole method of execution in the State since 1890 (hanging had been abolished in 1888). In 1965, the State of New York repealed the death penalty, except for cases involving the murder of a police officer. Although the legislature never fully repealed the death penalty statute, and the state even expanded it in 1995, there were no further executions because of rulings by the U.S. Supreme Court in 1972 and the New York Court of Appeals in 2004.
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.