Woodward v. Alabama, 134 S. Ct. 405

Woodward convicted of capital murder ( officer Keith Houts ) in Montgomery, Alabama.
Jury voted 8–4 that aggravating factors did not outweigh mitigating factors, recommending life without parole.
Trial judge conducted an additional sentencing hearing, heard new evidence, and overrode the jury to impose death.
Alabama law allows the judge to override jury verdicts because the jury’s decision is advisory, not binding.
Since Harris, Alabama is the only state permitting such overrides; numerous overrides have produced death sentences contrary to jury verdicts.
Sotomayor, J., dissenting from denial of certiorari, argues for revisiting Alabama’s judicial-override scheme under Sixth and Eighth Amendment concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alabama’s judicial override of a jury’s life verdict violates Apprendi/Ring principles	Woodward argues overrides violate jury fact-finding required for enhanced punishment	Alabama defends statutory override as constitutional	Certiorari denied (Court did not grant review)
Whether Alabama’s override mechanism risks arbitrary, capricious sentencing in violation of Eighth Amendment	Override undermines safeguards against arbitrariness	Statutory scheme is constitutional under precedent	Certiorari denied (Court did not grant review)

Furman v. Georgia, 408 U.S. 238 (U.S. 1972) (death penalty is fundamentally different and requires safeguards to avoid arbitrariness)
Gregg v. Georgia, 428 U.S. 153 (U.S. 1976) (established procedures to minimize arbitrariness in capital sentencing)
Spaziano v. Florida, 468 U.S. 447 (U.S. 1984) (upheld Florida’s judicial override (before reconsideration))
Harris v. Alabama, 513 U.S. 504 (U.S. 1995) (upheld Alabama’s judicial override; questioned now in light of Apprendi/Ring)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (facts increasing punishment must be found by a jury)