Beck v. Alabama
Encyclopedia
Beck v. Alabama, 447 U.S. 625 (1980) is a United States Supreme Court
case in which the Court held that a jury must be allowed to consider lesser included offense
s, not just capital offense or acquittal
.
Beck was participating in a robbery when his accomplice intentionally killed someone. Beck was tried for capital murder. Under the Code of Alabama, Section 13-11-2 (1975), the requisite intent to kill could not be supplied by the felony murder doctrine. Felony murder was thus a lesser-included offense of the capital crime of robbery with an intentional killing.
Under the statute, the judge was specifically prohibited from giving the jury the option of convicting for the lesser-included offense. Absent the statutory ban on such an instruction, Beck's testimony would have entitled him to an instruction on felony murder.
In the lower courts, Beck attacked the ban on the grounds that the Alabama statute was the same as the mandatory death penalty statutes that the Court had been striking down in recent holdings. Though the lower courts disagreed, the Supreme Court held that the failure to give the jury the option of convicting on a lesser-included offense inevitably enhanced the intolerable risk of an unwarranted death conviction.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case in which the Court held that a jury must be allowed to consider lesser included offense
Lesser included offense
A lesser included offense, in criminal law, is a crime for which all of the elements necessary to impose liability are also elements found in a more serious crime....
s, not just capital offense or acquittal
Acquittal
In the common law tradition, an acquittal formally certifies the accused is free from the charge of an offense, as far as the criminal law is concerned. This is so even where the prosecution is abandoned nolle prosequi...
.
Beck was participating in a robbery when his accomplice intentionally killed someone. Beck was tried for capital murder. Under the Code of Alabama, Section 13-11-2 (1975), the requisite intent to kill could not be supplied by the felony murder doctrine. Felony murder was thus a lesser-included offense of the capital crime of robbery with an intentional killing.
Under the statute, the judge was specifically prohibited from giving the jury the option of convicting for the lesser-included offense. Absent the statutory ban on such an instruction, Beck's testimony would have entitled him to an instruction on felony murder.
In the lower courts, Beck attacked the ban on the grounds that the Alabama statute was the same as the mandatory death penalty statutes that the Court had been striking down in recent holdings. Though the lower courts disagreed, the Supreme Court held that the failure to give the jury the option of convicting on a lesser-included offense inevitably enhanced the intolerable risk of an unwarranted death conviction.