## Facts

- Robert Franklin Godfrey’s marriage deteriorated; after a violent argument, his estranged wife left, sought divorce, and obtained a warrant charging him with aggravated assault.
- After she told him she would not live with him again, Godfrey went to his mother-in-law’s trailer with a shotgun.
- Godfrey shot his wife through a window, killing her instantly, then entered the trailer, struck his daughter with the shotgun barrel, and shot and instantly killed his mother-in-law.
- Godfrey contacted law enforcement, admitted responsibility, and led officers to the weapon.
- A Georgia jury convicted him of two murders and aggravated assault.
- In the penalty phase, the jury imposed death for both murders based on a statutory aggravating circumstance that the murders were “outrageously or wantonly vile, horrible or inhuman” because they involved “torture, depravity of mind, or an aggravated battery.”
- The trial court instructed the jury only in the statute’s language; the jury’s written findings used the generic “outrageously or wantonly vile, horrible and inhuman” formulation.
- The prosecution conceded there was no allegation of torture or aggravated battery, but the aggravator was nonetheless submitted and found.
- The Georgia Supreme Court affirmed the death sentences, rejecting a vagueness challenge and finding the evidence sufficient.

## Issues

1. Whether, as construed and applied in this case, Georgia’s “outrageously or wantonly vile, horrible or inhuman” aggravating circumstance satisfied the Eighth and Fourteenth Amendments by providing clear, objective standards that genuinely narrow and guide capital sentencing discretion.

## Decision

- The Court reversed the judgment insofar as it upheld the death sentences and remanded.
- A plurality concluded that the aggravator, as applied here, was too vague and broad to channel the sentencer’s discretion.
- The record showed sudden, instantaneous killings by shotgun blasts, with no evidence of torture, serious physical abuse beyond the killings, or comparable limiting features.
- The Georgia Supreme Court failed to apply a narrowing construction that would confine the aggravator to a defined subset of murders, allowing the death penalty to rest on open-ended characterizations.
- Concurring Justices agreed the death sentences could not stand; dissenting Justices would have affirmed based on deference to the state court’s application and the seriousness of the crimes.

## Legal Principles

- The Eighth and Fourteenth Amendments require capital sentencing schemes to avoid arbitrary and capricious outcomes by meaningfully guiding and limiting sentencing discretion.
- An aggravating circumstance must genuinely narrow the class of death-eligible defendants; adjectives of ordinary breadth that could cover many murders are insufficient without a consistent, objective limiting construction.
- A death sentence cannot rest on a state court’s application of an aggravator that functions as an unbounded catchall rather than a clear standard distinguishing the most aggravated murders from ordinary homicides.
- A facially approved aggravating factor may be unconstitutional as applied when the state fails to maintain and enforce a narrowing interpretation in practice.

## Conclusion

The Court set aside Godfrey’s death sentences because the “vile, horrible or inhuman” aggravator was applied without a consistent narrowing standard, permitting a death sentence to turn on subjective labels rather than objective criteria required by the Eighth and Fourteenth Amendments.


Godfrey v. Georgia, 446 U.S. 420 (1980)