## Facts

- Stanislaus Roberts was convicted in Louisiana of first-degree murder for killing a gas-station attendant during an armed robbery.
- Under Louisiana’s post-*Furman* first-degree murder statute, a guilty verdict in specified categories required an automatic death sentence, without any sentencing-phase discretion.
- The statutory scheme also required juries to be instructed on lesser included homicide offenses and permitted juries to return those lesser verdicts even if unsupported by the evidence.
- The Louisiana Supreme Court affirmed Roberts’s conviction and death sentence.
- Roberts sought review, arguing the mandatory death-penalty scheme violated the Eighth and Fourteenth Amendments.

## Issues

1. Whether Louisiana’s mandatory imposition of the death penalty upon conviction for specified first-degree murders violates the Eighth and Fourteenth Amendments.
2. Whether Louisiana’s requirement that juries consider lesser offense verdicts even when unsupported by evidence provides a constitutionally sufficient safeguard against arbitrary imposition of death.

## Decision

- The Supreme Court reversed the judgment upholding the death sentence and remanded, leaving the conviction intact.
- A plurality concluded the death penalty is not categorically barred by the Eighth Amendment.
- The Court held Louisiana’s mandatory death sentence for first-degree murder was unconstitutional because it did not permit individualized consideration of the offender or offense.
- The Court rejected the State’s claim that the lesser-offense “responsive verdict” structure cured the defect, reasoning it lacked guiding standards and encouraged arbitrary outcomes.

## Legal Principles

- A capital sentencing scheme must allow individualized consideration of the defendant’s character and record and the circumstances of the offense before death may be imposed.
- Mandatory death-penalty statutes that treat all offenders convicted of a defined offense as an undifferentiated class violate the Eighth and Fourteenth Amendments.
- Procedures that effectively shift sentencing discretion to unguided jury choices among lesser verdicts, including choices not supported by evidence, do not adequately prevent arbitrary and capricious capital outcomes.

## Conclusion

The Court invalidated Louisiana’s mandatory death sentence for first-degree murder because it barred consideration of mitigating circumstances and substituted an unstructured, potentially arbitrary jury mechanism for individualized capital sentencing, in violation of the Eighth and Fourteenth Amendments.


Roberts v. Louisiana, 428 U.S. 325 (1976)