Facts of the case
Christopher Simmons was sentenced to death in 1993, when he was only 17. A series of appeals to state and federal courts lasted until 2002, but each appeal was rejected. Then, in 2002, the Missouri Supreme Court stayed Simmon’s execution while the U.S. Supreme Court decided Atkins v. Virginia, a case that dealt with the execution of the mentally disabled. After the U.S. Supreme Court ruled that executing the mentally disabled (or mentally retardedin the vernacular of the day) violated the Eighth and 14th Amendment prohibitions on cruel and unusual punishment because a majority of Americans found it cruel and unusual, the Missouri Supreme Court decided to reconsider Simmons’ case.Using the reasoning from the Atkins case, the Missouri court decided, 6-to-3, that the U.S. Supreme Court’s 1989 decision in Stanford v. Kentucky, which held that executing minors was not unconstitutional, was no longer valid. The opinion in Stanford v. Kentucky had relied on a finding that a majority of Americans did not consider the execution of minors to be cruel and unusual. The Missouri court, citing numerous laws passed since 1989 that limited the scope of the death penalty, held that national opinion had changed. Finding that a majority of Americans were now opposed to the execution of minors, the court held that such executions were now unconstitutional.On appeal to the U.S. Supreme Court, the government argued that allowing a state court to overturn a Supreme Court decision by looking at evolving standardswould be dangerous, because state courts could just as easily decide that executions prohibited by the Supreme Court (such as the execution of the mentally ill in Atkins v. Virginia) were now permissible due to a change in the beliefs of the American people.
Why is the case important?
Respondent committed murder when he was age 17. He was tried and sentenced to death after he turned 18.
Whether it is permissible under the Eighth and Fourteenth Amendments to the Constitution of the United States to execute a juvenile offender who was older than 15 but younger than 18 when he committed a capital crime.
No. The Supreme Court of the United States first established the applicability of the Eight Amendment, as well a precedent of the application of the death penalty to minors. Traditionally, minors did not face capital punishment. It noted that a “consensus” of the country is against the application of the death penalty to juveniles.
The Supreme Court of the United States began with a review of objective indicia of consensus on juvenile capital punishment, as expressed by the enactments of legislatures that had addressed the question. Thirty states had prohibited the juvenile death penalty: 12 that had rejected the death penalty altogether and 18 that had maintained it but, by express provision or judicial interpretation, excluded juveniles from its reach. The Court noted that even in the 20 states without a formal prohibition on executing juveniles, the practice was infrequent. The Court held that this provided sufficient evidence that American society viewed juveniles as categorically less culpable than the average criminal and went on to provide three reasons: (1) the lack of maturity and an underdeveloped sense of responsibility were found in youth more often than in adults and were more understandable among the young (2) juveniles were more vulnerable or susceptible to negative influences and outside pressures, including peer pressure and (3) the character of a juvenile was not as well formed as that of an adult. The Court held that the Eighth Amendment prohibited the imposition of the death penalty on juvenile offenders under 18.
- Advocates: James R. Layton argued the cause for Petitioner Seth P. Waxman argued the cause for Respondent
- Petitioner: Donald P. Roper, Superintendent, Potosi Correctional Center
- Respondent: Christopher Simmons
- DECIDED BY:Rehnquist Court
- Location: Meramec River
|Citation:||543 US 551 (2005)|
|Granted:||Jan 26, 2004|
|Argued:||Oct 13, 2004|
|Decided:||Mar 1, 2005|