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 The United Kingdom retained the death penalty for high treason until 1998; however, this technicality was superseded by the absolute ban on the death penalty in 1976.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 penalty for felony murder in some cases but not others, and that the dividing line is the situation presented by "Tison". In "Coker v. Georgia," the Court had rejected the death penalty for rape because only one state—Georgia—allowed that punishment. Accordingly, the task for the Court was to count the number of states that allowed the death penalty for felony murder to see if the death penalty was a comparatively rare sanction for that crime. This enumeration was not as simple as it might seem at first. In 1982, 36 states authorized the death penalty. In four, felony murder was