en.wikipedia.org/wiki/Furman_v._Georgia

This names the California case incorrectly. The 1972 California Supreme Court decision that held capital punishment invalid under the California Constitution is People v. Anderson, reported at 6 Cal.3d 628. The Stanford Law School California Supreme Court archive lists the case under that title and citation.

This matters because the article later refers to the same case correctly as People v. Anderson, so the earlier mention is inconsistent with the actual case name.

This reverses what McGautha v. California actually held.

In McGautha, the Supreme Court described California’s capital procedure as two stages, with punishment decided in a separate proceeding after guilt. The opinion recounts that, at the penalty trial, evidence about the defendant’s background and facts in aggravation or mitigation was presented to the jury. The Court then held that Ohio was not constitutionally required to use California’s bifurcated approach.

So McGautha did not reject a sentencing phase where aggravating or mitigating evidence could be presented. It did the opposite: it upheld California’s separate penalty proceeding while also holding that the Constitution did not require every state to use one.

This is too broad. Furman v. Georgia was limited to whether imposing and carrying out the death penalty “in these cases” violated the Eighth Amendment, and the Court held the challenged discretionary death-penalty schemes unconstitutional as applied.

If Furman had already invalidated the death penalty for rape as a category, there would have been no need for Coker v. Georgia. But in Coker, the Supreme Court explained that after Furman, three states still provided the death penalty for the rape of an adult woman in revised statutes, and Georgia remained the only state still authorizing that punishment at the time of Coker. Coker is the case that held death to be a disproportionate punishment for rape of an adult woman.

So Furman invalidated the rape death sentences in Jackson and Branch, but it did not itself categorically invalidate the death penalty for rape.

This gets the lineup in Gregg v. Georgia wrong.

The controlling plurality in Gregg was the joint opinion of Justices Stewart, Powell, and Stevens — three Justices, not four. A fourth Justice may have agreed with some of the underlying reasoning in a separate opinion, but that does not make it part of the plurality opinion.

So describing the Gregg plurality opinion as one supported by “only four Justices” is inaccurate as written.