Enmund had waited in the getaway car while his two accomplices robbed a Florida farm. The plan went awry, and the accomplices killed the farm owners. Although Enmund neither killed anyone nor intended for anyone to be killed, the Florida Supreme Court concluded that his participation in a felony out of which a murder arose was enough to justify the death penalty. Applying the eighth amendment's cruel and unusual punishment clause, the Supreme Court reversed the Florida court and held that the death penalty could not be used for a co-felon who neither killed nor intended that a killing occur. The court purportedly relied on standards adopted in previous decisions, but its analysis was tenuous and inconclusive. In addition, it appeared to adopt a new eighth amendment requirement of proving specific intent. However, this requirement may prove difficult to apply, because the court failed to indicate the necessary level of intent. Thus, a future court will have to deal with the issues which the Enmund decision should have resolved. A total of 188 case notes are provided.