In Enmund v. Florida, the U.S. Supreme Court finds it to be “cruel and unusual punishment” to execute a defendant who drove the getaway car after a robbery resulting in a homicide (but who did not kill, or attempt to kill, anyone). The Court rules that the death penalty is too harsh a penalty to impose on such a minor participant in a felony murder (i.e., a murder that occurs in the course of another felony, such as robbery).