Roper v. Simmons
Roper v. Simmons is a landmark Supreme Court case decided in 2005 that addressed the constitutionality of imposing the death penalty on individuals who were minors at the time of their offense. The case stemmed from the conviction of Christopher Simmons, who was sentenced to death for the murder of Shirley Crook when he was seventeen. The Supreme Court, in a narrow 5-4 decision, ruled that executing minors constituted "cruel and unusual punishment," violating the Eighth and Fourteenth Amendments. This ruling relied on considerations of juvenile psychological development and evolving societal standards regarding capital punishment.
The case built upon previous rulings that had established a complex legal landscape concerning minors and the death penalty, including earlier cases that both restricted and permitted such sentences. Organizations like the American Psychological Association contributed amicus briefs presenting research on adolescent brain development and the implications for culpability. The decision in Roper v. Simmons not only overruled a prior case but also set a precedent influencing subsequent rulings, such as Graham v. Florida, which further limited the sentencing of juveniles. The case remains significant in discussions about juvenile justice and the moral and legal boundaries of state punishment.
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Roper v. Simmons
The Case: US Supreme Court ruling on constitutionality of capital punishment for minors
Date: Decided on March 1, 2005
Deferring to international standards, national trends, and the psychological limitations of juveniles, the Supreme Court ruled that imposing capital punishment on minors was “cruel and unusual” and thus unconstitutional. Addressing its patchwork of cases that assessed minors and the death penalty, the court created a more comprehensive stance to reflect, in the words of Justice Anthony Kennedy, its “evolving standards of decency.”
In 1993, seventeen-year-old Christopher Simmons was accused of murdering forty-six-year-old Shirley Crook. Initially given the death penalty, his sentence was commuted to life in prison after he claimed a lack of effective council. The state of Missouri appealed this ruling, and the case rose to the US Supreme Court.
Prior to hearing Roper v. Simmons, the Supreme Court had issued mixed rulings on capital punishment. In 1988, the court ruled in Thompson v. Oklahoma against issuing the death penalty to offenders under sixteen. Later, in Stanford v. Kentucky (1989), the court allowed capital punishment for those aged sixteen and older. That same year, the court upheld capital punishment for the mentally handicapped in Penry v. Lynaugh. Leading up to Roper v. Simmons, the court heard Atkins v. Virginia (2002), which overruled Penry on the basis of cruel and unusual punishment.
Supporting Simmons, the American Psychological Association (APA) and the Coalition for Juvenile Justice (CJJ) filed amicus briefs. The APA questioned the sufficient development of adolescents, citing that brain development in the area of decision making continued into young adulthood. The APA contended that as minors were not fully developed, their threat to society was not able to be determined. Joining them, the CJJ referenced development issues and emphasized the trend of wrongful imprisonment and sentencing for minors, which was often based on coercion and faulty confessions. Both groups claimed that imposing capital punishment on minors robbed them of basic rights.
Under a close decision of five to four, the Supreme Court ruled in favor of Simmons. Justice Anthony Kennedy delivered the majority opinion, citing the Eighth and Fourteenth Amendments and linking the Atkins case to assertions of limited development in minors. The ruling overturned Stanford v. Kentucky.
Impact
Utilizing an inclusive view of cruel and unusual punishment, the Roper v. Simmons decision inspired greater leniency in sentencing juvenile offenders. This stance influenced the court’s decision in Graham v. Florida (2010), which prohibited life in prison without parole for minors convicted of all crimes excluding murder.
In addition, the Roper v. Simmons ruling questioned the court’s deliberation process. While the decision was made on constitutional grounds, it also considered international views and state trends regarding capital punishment. Critics argued against the use of such views—external to law—to decide the case and create these “evolving standards of decency.” The use of such external sources called into question what bound the court to US law and the Constitution itself.
Bibliography
Garland, David, Randall McGowen, and Michael Meranze, eds. America’s Death Penalty: Between Past and Present. New York: NYU P, 2011. Print.
Tydings, Joseph D., et al. “Brief of the Coalition for Juvenile Justice as Amicus Curiae in Support of Respondent.” Coalition for Juvenile Justice. Coalition for Juvenile Justice, 19 July 2004. Web. 12 Oct. 2012.