Atkins v. Virginia Case Brief

Facts of the case

Daryl Renard Atkins was convicted of abduction, armed robbery, and capital murder. In the penalty phase of Atkins’ trial, the defense relied on one witness, a forensic psychologist, who testified that Atkins was mildly mentally disabled (or mentally retardedin the vernacular of the day). The jury sentenced Atkins to death, but the Virginia Supreme Court ordered a second sentencing hearing because the trial court had used a misleading verdict form. During resentencing the same forensic psychologist testified, but this time the State rebutted Atkins’ intelligence. The jury again sentenced Atkins to death. In affirming, the Virginia Supreme Court relied on Penry v. Lynaugh, in rejecting Atkins’ contention that he could not be sentenced to death because he is mentally retarded.

Why is the case important?

Atkins contention was that the execution of a mentally retarded criminal is a cruel and unusual punishment which contravenes the Eighth Amendment. He made this contention when he was sentenced to death for committing murder. Atkins (D) had an IQ 0f 59 at the time of his conviction.

Question

Under the Eighth Amendment, is the capital punishment of a mentally retarded convict cruel and unusual?

ANSWER

(Stevens, J.) Yes. Under the Eighth Amendment, the capital punishment of a mentally retarded convict is cruel and unusual. Mentally retarded persons should be tried and punished when they commit crimes once they meet the law’s requirement. Mentally retarded persons do not act with the level of moral culpability that characterizes the most serious adult criminal conduct because of their disabilities in the areas of reasoning, control of impulses and judgment. Hence, the enactment of the federal government which exempts the mentally retarded from execution has provided a strong evidence in which the society view the mentally retarded offenders as less culpable than the average criminal. The mentally retarded person’s disposition often portrays that they lack remorse for their crimes and they are also poor witnesses because they are not capable of assisting their counsel. Reversed and remanded.

CONCLUSION

In both penalty phases, the defense relied on the conclusion of a forensic psychologist that the defendant was mildly mentally retarded. The Court noted that the practice of executing mentally retarded criminals had become truly unusual, and concluded that a national consensus had developed against it. Construing and applying the Eighth Amendment in the light of evolving standards of decency, the Court concluded that such punishment was excessive and that the U.S. Constitution places a substantive restriction on a state’s power to take the life of a mentally retarded offender. The Court reasoned that the deficiencies of mentally retarded criminals do not warrant an exemption from criminal sanctions, but they do diminish their personal culpability. Mentally retarded defendants in the aggregate face a special risk of wrongful execution. The Court noted that there was more disagreement about how to determine which offenders are in fact retarded than over whether or not the death penalty is appropriate for them. The Court stated that it would leave to the states the task of developing appropriate ways to enforce the constitutional restriction upon its execution of sentences.

  • Advocates: James W. Ellis Argued the cause for the petitioner Pamela A. Rumpz Argued the cause for the respondent
  • Petitioner: Atkins
  • Respondent: Virginia
  • DECIDED BY:Rehnquist Court
  • Location: York County Court
Citation: 536 US 304 (2002)
Argued: Feb 20, 2002
Decided: Jun 20, 2002
Atkins v. Virginia Case Brief