Atkins v. Virginia
Atkins v. Virginia | |
---|---|
Subsequent | Remanded to Circuit Court, 581 S.E.2d 514 (Va. 2003) |
Holding | |
A Virginia law allowing the execution of mentally disabled individuals violated the Eighth Amendment's prohibition of cruel and unusual punishments. Supreme Court of Virginia reversed and remanded. | |
Court membership | |
| |
Case opinions | |
Majority | Stevens, joined by O'Connor, Kennedy, Souter, Ginsburg, Breyer |
Dissent | Rehnquist, joined by Scalia, Thomas |
Dissent | Scalia, joined by Rehnquist, Thomas |
Laws applied | |
U.S. Const. amend. VIII | |
This case overturned a previous ruling or rulings | |
Penry v. Lynaugh |
Atkins v. Virginia, 536 U.S. 304 (2002), is a case in which the Supreme Court of the United States ruled 6–3 that executing people with intellectual disabilities violates the Eighth Amendment's ban on cruel and unusual punishments, but that states can define who has an intellectual disability.[1] At the time Atkins was decided, just 18 of the 38 death penalty states exempted mentally disabled offenders from the death penalty.[2]
Twelve years later in Hall v. Florida the U.S. Supreme Court narrowed the discretion under which U.S. states can designate an individual convicted of murder as too intellectually incapacitated to be executed.[3]
Background
Around midnight on August 16, 1996, following a day spent together by drinking alcohol and smoking marijuana, the 18-year-old Daryl Renard Atkins (born November 6, 1977) and his accomplice, William Jones, walked to a nearby convenience store, where they abducted Eric Nesbitt, an airman from nearby
Footage of Atkins and Jones in the vehicle with Nesbitt was captured on the ATM's
During the penalty phase of the trial, the defense presented Atkins's school records and the results of an
On appeal, the
Because of what it perceived to be a shift in the judgments of state legislatures as to whether intellectually disabled people are appropriate candidates for execution in the 13 years since Penry had been decided, the Supreme Court agreed to review Atkins's death sentence. The Court heard oral arguments in the case on February 20, 2002.
Decision
The Eighth Amendment forbids cruel and unusual punishments. The ruling stated that unlike other provisions of the Constitution, the Eighth Amendment should be interpreted in light of the "evolving standards of decency that mark the progress of a maturing society." The best evidence on that score was determined to be the judgment of state legislatures. Accordingly, the Court had previously found that the death penalty was inappropriate for the crime of
The Court then described how a national consensus that intellectually disabled people should not be executed had emerged. In 1986,
Also, the "relationship between mental retardation and the penological purposes served by the death penalty" justifies a conclusion that executing intellectually disabled people is cruel and unusual punishment that the Eighth Amendment should forbid. In other words, unless it can be shown that executing the intellectually disabled promotes the goals of
Because intellectually disabled people cannot communicate with the same sophistication as the average offender, there is a greater likelihood that their deficiency in communicative ability will be interpreted by juries as a lack of remorse for their crimes. They typically make poor witnesses and are more prone to suggestion and willing to "confess" to placate or please their questioner. Thus, there is a greater risk that the jury may impose the death penalty despite the existence of evidence that suggests that a lesser penalty should be imposed. In light of the "evolving standards of decency" that the Eighth Amendment demands, the fact that the goals of retribution and deterrence are not served as well in the execution of intellectually disabled people, and the heightened risk that the death penalty will be imposed erroneously, the Court concluded that the Eighth Amendment forbids the execution of intellectually disabled people.
In dissent, Justices Antonin Scalia, Clarence Thomas and Chief Justice William Rehnquist argued that in spite of the increased number of states that had outlawed the execution of intellectually disabled people, there was no clear national consensus, and even if one had existed, the Eighth Amendment provided no basis for using such measures of opinion to determine what is "cruel and unusual." Justice Antonin Scalia commented in his dissent that "seldom has an opinion of this court rested so obviously upon nothing but the personal views of its members." The citing of an amicus brief from the European Union also drew criticism from Chief Justice Rehnquist, who denounced the "Court's decision to place weight on foreign laws."[4]
Subsequent Supreme Court decisions
Twelve years after its Atkins decision the U.S. Supreme Court narrowed in Hall v. Florida (2014) the discretion under which U.S. states can designate an individual convicted of murder as too intellectually incapacitated to be executed.[3] The Court laid down as a legal rule that "if the individual claiming intellectual incapacity has an IQ score that falls somewhere between 70 and 75, then that individual's lawyers must be allowed to offer additional clinical evidence of intellectual deficit, including, most importantly, the inability to learn basic skills and [to] adapt how to react to changing circumstances."[3]
In Moore v. Texas (2017) the Supreme Court stated although the states have the primary responsibility for "the task of developing appropriate ways to enforce" the Eighth Amendment's prohibition of executing intellectually disabled persons, they can't do this in the way they want. States must closely take into account the most recent medical guide on intellectual disabilities.[5][6] "A diagnosis of intellectual disability requires three things: 1) significantly subaverage intellectual functioning (typically measured by an IQ score roughly two standard deviations below the mean); 2) adaptive-functioning deficits; and 3) an onset during childhood, before reaching 18. As the court recognized in Hall v. Florida (2014), intellectual disability is a condition, not an IQ score, and proper diagnosis thus places great emphasis on the second requirement, related to adaptive functioning."[7] The Court further decided that instead of stereotypes, science should govern death penalty cases involving intellectually-disabled prisoners[7] and that courts should base their decisions on opinions of professional organizations like the American Psychological Association.[8]
Subsequent developments for Daryl Atkins
A jury in
In January 2008, Circuit Court Judge Prentis Smiley, who was revisiting the matter of whether Atkins was mentally disabled, received allegations of prosecutorial misconduct. Those allegations, if true, would have authorized a new trial for Atkins. After two days of testimony on the matter, Smiley determined that prosecutorial misconduct had occurred. At that juncture, Smiley could have vacated Atkins's conviction and ordered a new trial. Instead, Smiley determined the evidence was overwhelming that Atkins had participated in a
Prosecutors sought writs of
See also
- List of United States Supreme Court decisions on capital punishment
- List of United States Supreme Court cases, volume 536
- List of United States Supreme Court cases
- Bigby v. Dretke
- Hall v. Florida – 2014 U.S. Supreme Court case limiting the death penalty in the wake of Atkins v. Virginia
- Monster (Walter Dean Myers novel)
Footnotes
- ^ Cohen, Andrew (October 22, 2013). "At Last, the Supreme Court Turns to Mental Disability and the Death Penalty". The Atlantic. Retrieved October 26, 2013.
- JSTOR 40040587.
- ^ a b c Denniston, Lyle (May 27, 2014). "Opinion analysis: A new limit on the death penalty". SCOTUSblog. Archived from the original on November 12, 2020. Retrieved May 29, 2014.
- ^ Buonomo, Giampiero (June 2006). "Il diritto straniero e la Corte suprema statunitense". Quaderni Costituzionali (in Italian). 26 (2).
- ^ Howe, Amy (March 28, 2017). "Opinion analysis: A victory for intellectually disabled inmates in Texas". SCOTUSblog. Archived from the original on October 10, 2020. Retrieved December 15, 2020.
- ^ Howe, Amy (February 19, 2019). "Justices take up Clean Water Act case, rebuke Texas court in death penalty case". SCOTUSblog. Archived from the original on November 12, 2020. Retrieved December 13, 2020.
- ^ a b Brian Stull (June 27, 2017). "Death-penalty symposium: The court keeps treating a fatally diseased death penalty". SCOTUSblog. Archived from the original on October 10, 2020. Retrieved December 15, 2020.
- ^ Dominic Draye (June 27, 2015). "Death-penalty symposium: Evolving standards for "evolving standards"". SCOTUSblog. Archived from the original on October 9, 2020. Retrieved December 15, 2020.
- ^ Liptak, Adam (January 19, 2008). "Lawyer Reveals Secret, Toppling Death Sentence - New York Times". www.nytimes.com. Retrieved July 8, 2008.
- ^ Liptak, Adam (February 8, 2008). "Virginia: Inmate Will Remain on Death Row". www.nytimes.com. Retrieved November 20, 2008.
- ^ "Virginia Supreme Court vacates death sentence for Daryl Atkins. In: Projekt Press Newsletter Summer 2009 of the ABA Death Penalty Representation Project". American Bar Associationen. May 4, 2020. Archived from the original on December 13, 2020. Retrieved December 13, 2020.
External links
- Text of Atkins v. Virginia, 536 U.S. 304 (2002) is available from: Cornell Findlaw Google Scholar Justia Library of Congress Oyez (oral argument audio)
- Transcript of oral argument
- Information about Atkins from the Death Penalty Information Center, an anti-capital punishment clearinghouse
- "Killer's fate hanging on his IQ" at BBC News
- Information about applying Atkins from the American Psychiatric Association
- Amicus brief of the Criminal Justice Legal Foundation
- Amicus brief of the American Association on Mental Retardation
- Virginia Supreme Court Opinion in Atkins v. Commonwealth including dissents of Hassell and Koontz
- Blog entry from the Daily Kos