While the Supreme Court has suggested that a mandatory death penalty may be the only adequate means of deterring lifers from murder, it has never definitively addressed this issue. An analysis of whether a mandatory death penalty has greater deterrence value than a discretionary death penalty demonstrates that mandating execution upon conviction will have no more than a minimal effect on what a potential murderer perceives as the risks of apprehension, prosecution, conviction, and punishment. The potential of a mandatory death penalty to somewhat increase the certainty of punishment perceived by a very limited number of life-term inmates should not lead courts or legislatures to strip capital sentencing of all procedural safeguards. Sacrificing the established constitutional mandate of individualized consideration would result in executions regardless of the presence of mitigating circumstances. If there is a constitutional justification for such a sacrifice, one is hard pressed to find it in the need to deter lifers from murdering. 270 footnotes.