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
The Supreme Court of the United States has held that the Eighth Amendment to the United States Constitution does not prohibit imposing the death penalty for felony murder. The Supreme Court has created a two-part test to determine when the death penalty is an appropriate punishment for felony murder. Under "Enmund v. Florida", the death penalty may not be imposed on someone who did not kill, attempt to kill, or intend that a killing take place. However, under "Tison v. Arizona", the death penalty "may" be imposed on someone who was a major participant in the underlying felony and acted with reckless indifference to human life.