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 rule
, 46 states in the United States have a felony murder rule, under which felony murder is generally first-degree murder. In 24 of those states, it is a capital offense. When the government seeks to impose the death penalty on someone convicted of felony murder, the Eighth Amendment has been interpreted so as to impose additional limitations on the state power. The death penalty may not be imposed if the defendant is merely a minor participant and did not actually kill or intend to kill. However, the death penalty may be imposed if the defendant is a major participant in the underlying felony and exhibits extreme indifference to human life.