Godfrey v. Georgia

Godfrey (defendant) and his wife split up after repeated domestic arguments, and the wife left to live with her mother. The two had several heated telephone conversations where Godfrey pleaded with his wife to come home and the wife stated that reconciliation was impossible. After the last conversation, Godfrey took a shotgun, walked to the house where his wife was staying, and killed his wife and her mother. He called the sheriff after his actions and admitted everything to the police department. He pleaded not guilty at the trial by reason of temporary insanity, but was convicted of two counts of murder. At sentencing, the judge instructed the jury to consider subsection (b)(7) of Georgia law, which stated that an individual convicted of murder could be sentenced to death if the offense was “outrageous or wantonly vile, horrible, or inhuman.” This statute was known as the statutory aggravating circumstance statute. After these instructions, the jury sentenced Godfrey to death. Godfrey appealed his sentence to the state supreme court, stating that the jury was incorrect in sentencing him to death because the jury was too arbitrary in its interpretation of the subsection of the statute instructed to them. The Georgia Supreme Court upheld the sentence, stating that the jury’s finding of a statutory aggravating circumstance was supported by the evidence and was not arbitrary. The United States Supreme Court granted certiorari.