Roper v. Simmons

by:

Following is the case brief for Roper v. Simmons, 543 U.S. 551 (2005).

Case Summary of Roper v. Simmons:

  • Simmons, age 17, planned and committed a capital murder.  He was sentenced to death.  His direct appeal and petitions for relief were rejected.
  • When the Supreme Court decided Atkins v. Virginia in 2002 (barring executions for the mentally disabled), Simmons filed a new petition.  He argued that the Eighth Amendment rationale of Atkins should also bar the execution of juveniles.
  • The Missouri Supreme Court agreed and changed Simmons’s sentence to life without parole.
  • The U.S. Supreme Court affirmed.  It held that executing juvenile offenders under the age of 18 violates the Eighth and Fourteenth Amendments.

Roper v. Simmons Case Brief

Statement of the Facts:

In 1993, Christopher Simmons, age 17, devised a plan to burglarize a woman’s home and then murder her.  He brought two younger friends into the plot.  On the night of the murder, one friend opted out of the plan.  Simmons and the remaining friend broke into the victim’s home, bound her with duct tape, drove to a bridge, and threw her over the bridge into the river below.

Simmons confessed to the police.  He also gave a videotaped reenactment of the murder.  Evidence at Simmons’s trial established that Simmons planned the murder ahead of time and bragged about it afterwards.  The jury found Simmons guilty and recommended the death penalty, which the trial court imposed.

Procedural History:

After exhausting his direct appeals and other petitions for relief, Simmons filed a new post-conviction relief petition in Missouri state court after the U.S. Supreme Court decided Atkins v. Virginia, 536 U.S. 304 (2002), which overturned the death penalty for the mentally disabled.  The Missouri Supreme Court applied the reasoning in Atkins to offenders under age 18, and changed Simmons’s sentence to life in prison without parole.  The State of Missouri appealed to the U.S. Supreme Court.  The Court granted certiorari.

Issue and Holding:

Is it constitutionally permissible to impose the death penalty on a juvenile offender who was under the age of 18 when he committed a capital crime?  No.

Judgment:

The judgment of the Missouri Supreme Court is affirmed.

Rule of Law or Legal Principle Applied:

It is unconstitutional to sentence someone to the death penalty for a crime committed when that person was under the age of 18.

Reasoning:

In previous cases, the Court barred executions for criminals under the age of 16, and for the mentally disabled.  Now, the Court finds that the evolving standards of decency demonstrate that the execution of criminals younger than 18 years old would constitute “cruel and unusual punishment” under the Eighth Amendment.  Here are the main reasons:

  • National consensus indicates that executions for juvenile offenders under 18 are rare.  Also, most states already reject imposition of the death penalty for those under 18.
  • Three general differences between juvenile and adult offenders show that juveniles should be treated differently with regard to the ultimate punishment of death:  (i) juveniles display a lack of maturity and responsibility compared to adults; (ii) juveniles are more susceptible to negative influences and pressures; (iii) a juvenile’s character is not as well formed as an adult’s.
  • The goals of retribution and deterrence do not provide adequate justification for imposing the death penalty on juveniles.
  • The United States is the only country in the world that gives official sanction to the execution of juvenile offenders.  Although international norms do not govern our laws, they are instructive to the Court.

Concurring and Dissenting Opinions:

Concurring Opinion (Stevens):

Justice Stevens applauds the Court’s reaffirmation that the evolving standards of decency should drive the interpretation of the Bill of Rights.

Dissenting Opinion (O’Connor):

Justice O’Connor does not find that there is a national consensus with regard to imposing the death penalty on juveniles.

Dissenting Opinion (Scalia):

Justice Scalia takes fundamental issue with the notion of “evolving standards of decency.”  He cannot see how the U.S. Constitution could have changed since the Court decided that age 16 would be the bar to executions.

Significance:

Roper v. Simmons is a landmark decision because it bars the use of the death penalty on juveniles in the United States.  It also sparked controversy with regard to (i) the continued use of the “evolving standards of decency” and “national consensus” rationales to re-interpret previous rulings, and (ii) the use of foreign laws and norms to interpret U.S. law.

Student Resources:

https://supreme.justia.com/cases/federal/us/543/551/

https://www.law.cornell.edu/supct/html/03-633.ZO.html

https://www.oyez.org/cases/2004/03-633