St. John's Law Review

Better Dead than R(ap)ed?: The Patriarchal Rhetoric Driving Capital Rape Statutes

By:  Corey Rayburn

“It is true rape is a most detestable crime, and therefore ought severely and impartially to be punished with death; but it must be remembered, that it is an accusation easily to be made and hard to be proved, and harder to be defended by the party accused, tho never so innocent.”  Sir Matthew Hale, 1676

Hale’s oft-cited words are more famous for their bearing on the procedural aspects of rape law, but it is the first part of the quote that relates to this article.  While little has changed since Hale’s time in how a rape trial proceeds, the application of the death penalty to rapists that he so vehemently supported fell into disfavor during the 1970’s in America and abroad.  The last time a person in the United States was executed for rape was forty years ago in Mississippi.  The movement in the United States against the death penalty for rape culminated in 1978 with the Supreme Court’s decision in Coker v. Georgia.  After the Court held that executions for rape were cruel and unusual punishment in violation of the Eighth Amendment of the Constitution, there was little left to be debated about the issue.

Or so we thought.  Efforts to revive the death penalty for the crime of rape in the United States gained a foothold in Louisiana in 1995.  On June 17 of that year, Governor Edwin Edwards signed into law provisions that allowed capital punishment for those convicted of raping a child.  The passage of a child rape death penalty statute in Louisiana set off a series of debates in state legislatures throughout America.  Those deliberations coincided with similar reviews of criminal penalties for rape around the world.  The fervor that has erupted regarding child molestation is not new, but the desire to apply the death penalty to these crimes has gained momentum in recent years.  Calls for law and order and the salient belief that child molesters cannot be rehabilitated have made the death penalty an attractive solution to a “tough on crime” public in the United States.  That these laws may conflict with the Court’s holding in Coker is not generally a consideration for those seeking swift “justice.”  Then again, that is not the concern of this article either.

While it is certainly important to speculate on what the Supreme Court would decide in a hypothetical case concerning the death penalty as applied to child rape, it is also critical to examine the legal effects these policies will have on womyn, children, and rapists.  Primarily, careful scrutiny must be applied to the proposition offered by some observers that “death sentences under the new statutes would not be vulnerable to arguments . . . that they are vestiges of viewing rape victims as male property.”  Many believe that because the new laws target child molesters, the issue of gender is irrelevant to the discussion.  Despite the abundance of material connecting feminist criticism to rape, some commentators act as though the Louisiana statute—and others like it—can escape these critiques by merely changing the “protected” group targeted by the law from womyn to children.

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Section I of this article will examine the history of the death penalty’s application in rape cases with emphasis on Western legal systems.  Section II will speak to the rhetoric underlying the legislative and judicial moves toward reviving the death penalty for rape.  Section III will analyze the policy and legal effects caused by the new statutes and the language supporting them.  Section IV will offer some conclusions and a few observations about the direction rape law is taking under these new statutory regimes.

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