Summary of Roper v. Simmons

Relevant Facts: Convicted for a crime he committed as a minor, but for which he was charged as an adult, Christopher Simmons was sentenced to receive the death penalty when he was 17 years old.  Simmons’ counsel filed numerous appeals against the sentencing, all of which were denied (this occurred until 2002).  In 2002, the Missouri Supreme Court stayed Simmons’ execution as the prudent course of action to take while the United States Supreme Court debated a similar matter, Atkins v. Georgia, i.e. the sentencing of death for the mentally ill convicted of death qualifying cases.  The Supreme Court ultimately ruled that executing the mentally ill did in fact violated the Eighth and Fourteenth Amendments preventing cruel and unusual punishment. on the grounds that a majority of Americans found the punishment to be unconscionable.  Consequently, the Missouri Supreme Court decided to revisit this case.  When the matter was revisited by the Missouri Supreme Court, the Court reasoned that per similar (previous) decisions, minors could not be executed without such punishment automatically constituting cruel and unusual punishment.  The government, on appeal to the United States Supreme Court, asserted that an ultimate decision on the matter was needed because letting states decide “evolving standards” with respect to national consensus on criminal justice matters would be inappropriate and thus dangerous.

Issue:  The legal question presented was whether the execution of minors violates the Eighth and Fourteenth Amendments, constituting cruel and unusual punishment.

Holding: The Court held that executing minors does constitute cruel and unusual punishment and therefore violating the Eighth and Fourteenth Amendments.

Majority Opinion:  The Court reasoned that executing minors does not comport with contemporary standards of decency.  Furthermore, the Court (majority) found that not only is capital punishment for minors incompatible with evolving standards of decency within the United States, but also within the broader international community.  The Court also relied upon psychiatric and sociological evidence that suggests that juveniles are for all intents and purposes mentally inferior to their adult counterparts, and thus incapable of the same impulse control that is demanded of adults who commit crimes.  Accordingly, they somewhat have a natural defect –immaturity – that prevents them from not acting out in cases such as Simmons’.

Dissenting Opinion:  Chief Justice Rehnquist, along with Associate Justices Scalia, O’Connor, and Thomas all dissented.  Chief Justice Rehnquist, and Associate Justices Scalia and Thomas premised their dissent on the fact that contrary to what was presented in the majority opinion, the correlation between juries not imposing capital punishments for juveniles on a wide scale did not positively indicate that juveniles should not be killed, but rather that not enough of them are committing such depraved and egregious qualifying crimes to warrant such a punishment.  The justices thus argued that there was not ample evidence presented on the primary rationale for why the majority overturned the practice.  In an equally interesting move, Justice O’Connor dissented on the grounds that states had not in fact moved away from imposing the death penalty.  Rather, states had used more forethought in articulating the types of cases in which such a punishment could be imposed, e.g. juveniles must be a minimum age of 16 or 17.  O’Connor also noted that on psychological grounds, while adolescents surely are apt to more impulsive behavior compared to the average adult, who bio-medically speaking, have reached neurological and by extension mental maturity (overall) by their early twenties, they nevertheless have the moral wherewithal (or should) not to engage in such crimes that would subject them to the penalty.  In short, teenagers may be impulsive but they are not beyond reproach simply on the basis on their young(er) age.

Conclusion:  The Roper v. Simmons case was incredibly significant in that it, along with the Atkins case, for the first time in U.S. jurisprudence, the USSC had ruled that regardless of the individual factors of cases, e.g. depravity, cruelty, etc., neither minors nor the mentally ill – the typically most vulnerable groups in society – could not be punished with the death penalty because doing so would be ethically problematic  on biomedical, psychiatric and moral (cruel and unusual punishment) grounds.