Atkins v. Virginia

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Following is the case brief for Atkins v. Virginia, Supreme Court of the United States, (2002)

Case summary for Atkins v. Virginia:

  • Daryl Atkins has an IQ of 59 and was sentenced to death for robbing and murdering a man at gun point.
  • Atkins appealed his death sentence to the United States Supreme Court, claiming it violated the Eighth Amendment.
  • The Supreme Court held that sentencing a mentally retarded individual to death violates the Eighth Amendment because a mentally retarded person cannot appreciate the purpose of capital punishment, retribution and deterrence, due to their cognitive deficiencies.
  • In addition, the Court held that mentally retarded individuals are not as mentally equipped to aid their counsel in constructing their own defense as an individual of average intelligence.

Case Brief for Atkins v. Virginia

Statement of the facts:

Daryl Atkins and William Jones captured and robbed Eric Nesbitt. After driving Nesbitt to an ATM and demanding him to withdraw additional cash at gun point, the two shot and killed their victim. Subsequent to their arrest, Atkins and Jones were charged with capital murder, armed robbery and abduction. A forensic Dr. for the defense testified that Atkins was mildly mentally retarded as his IQ was a 59. The Dr. based the conclusion off of high school transcripts, court records and the average human IQ, which stands at 100. After trial, Atkins was convicted of all three charges and sentenced to death. In response, Atkins appealed to the United States Supreme Court.

Procedural History:

Atkins appealed his death sentence to the Supreme Court of the United States and the Court granted certiorari.

Rule of Law or Legal Principle Applied:

Performing capital punishment on a mentally handicapped person constitutes cruel and unusual punishment, violating the Constitution’s Eighth Amendment.

Issue and Holding:

Does sentencing a mentally retarded person to death violate the Eighth Amendment’s prohibition against cruel and unusual punishment? Yes.

Judgment:

The Court reversed the state court’s judgment.

Reasoning:

The Court held that the Eighth Amendment expressly states, “[e]xcessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishment inflicted.”  The Court then looks to its decision in Penry v. Lynaugh, 492 U.S. 302 (1989), where the issue as to whether the death penalty should apply to mentally retarded persons was addressed. In Trop v. Dulles, 356 U.S. 86 (1958), Justice Warren outlined the Eighth Amendment and how it “must draw its meaning from the evolving standards of decency that mark the progress of a maturing society.”  The Court held that the level of review under those evolving standards should be objective issues like state legislation. The Court has previously held that death is not a proper sentence in cases where a life was not lost, such as rape. The Court used Georgia as an example which in 1986 led to the first statute prohibiting these kinds of executions.

Two years later Congress reinstated the death penalty stating that it did not apply to those who were mentally retarded and since then several states have enacted statutes similar to Georgia.

The Court then provides two reasons as to why the mentally disabled should not be subject to execution.  The question of whether the general justifications, retribution and deterrence, for imposition of the death penalty, should apply to mentally retarded offenders must be answered. According to Gregg v. Georgia, 428 U.S. 153 (1976) retribution implies that the severity of the punishment depends on the offender’s culpability.

Under this theory, if the average murderer’s actions do not warrant imposing the death penalty, then the lower level of culpability possessed by the mentally retarded offender does not merit the punishment.  Additionally, the exact deficiencies, which makes a mentally retarded defendants less morally culpable, make them less capable of understanding and controlling certain impulses they may have.

Deterrence does not impact a mentally retarded offender the same way it does a normal person as their cognitive functions are deficient. In addition, mentally retarded offenders could be less able to provide assistance to counsel in constructing their defense.

Concurring or Dissenting opinion:

Dissent (Scalia, J.)

The majority’s decision holds no support rooted in either the Eighth Amendment or current social opinions. It is important to note that less than half of the 38 states that currently allow capital punishment possess legislation prohibiting execution of mentally retarded persons.  In addition, the majority’s retribution argument fails to consider that culpability of an offender depends on the gravity of the crime, the individuals mental capacities and each should be balanced when assessing a penalty.

Significance:

This is the landmark case which set out that sentencing a mentally retarded person to death violates the Eighth Amendment’s prohibition against cruel and unusual punishment.

Student Resources:

https://www.law.cornell.edu/supct/html/00-8452.ZO.html
https://supreme.justia.com/cases/federal/us/536/304/