Capital punishment in Europe rights became a particular priority. The Kingdom of Italy had abolished the death penalty for civilians with the adoption of the Zanardelli Penal Code of 1889, but the Fascists had reintroduced it with the 1930 Penal Code. The European Convention on Human Rights was adopted in 1950, but some countries took many years to ratify it. The United Kingdom retained the death penalty for high treason until 1998; however, this technicality was superseded by the absolute ban on the death penalty in 1976. William Joyce was the last person to be put to death for high treason in the UK,
Felony murder and the death penalty in the United States a mandatory death penalty statute because it failed to provide for individualized consideration at sentencing. The rule fashioned by "Enmund" and "Tison" accommodated this concern by ensuring that only felony murder defendants who had a sufficiently culpable mental state received the death penalty. In an earlier case the Court had remarked that "capital punishment can serve as a deterrent only when murder is the result of premeditation and deliberation." The "Tison" rule retreats from this belief with its implicit assessment that the death penalty can deter even those who act recklessly. "A narrow focus on the question of whether or