Stanford v. Kentucky

Following is the case brief for Stanford v. Kentucky, 492 U.S. 361 (1989)

Case Summary of Stanford v. Kentucky:

  • Kevin Sanford, 17, committed a horrible rape and murder in Kentucky.  Heath Wilkins, 16, committed a similarly horrible murder in Missouri.
  • Both individuals were sentenced to death.
  • The Kentucky and Missouri Supreme Courts affirmed the death penalty in their respective cases.
  • The U.S. Supreme Court affirmed, holding that there was no national consensus regarding whether executing those under 18 years old is cruel and unusual under the Eighth Amendment.

Stanford v. Kentucky Case Brief

Statement of the Facts:

This case involves two separate cases in which juveniles were sentenced to death for committing particularly heinous crimes.  The first juvenile, Kevin Sanford, committed a horrific robbery, rape, and murder of a 20-year-old woman in Kentucky.  He was 17 years old at the time of the crime.  The second juvenile, Heath Wilkins, brutally stabbed a female convenience store clerk multiple times, killing her in Missouri.  He was 16 and a half years old.

Both States had laws that allowed for the execution of people under 18 years old for those who were transferred up to adult court because of the horrific nature of their crimes.  Kentucky permitted the death penalty for those over the age of 16, and Missouri for those over the age of 14.  Sanford was convicted by a jury and sentenced to death.  Wilkins pleaded guilty to his crimes and welcomed his sentence of death.

Procedural History:

  • The Supreme Court of both States affirmed the death sentences.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does the death sentence for a person who committed the crime as a 16 or 17 year old violate the Eighth Amendment’s prohibition against cruel and unusual punishment?  No.

Judgment:

The decisions of the Kentucky and Missouri Supreme Courts are affirmed.

Rule of Law or Legal Principle Applied:

The death penalty for a person who committed the crime as a 16 or 17 year old does not constitute cruel and unusual punishment under the Eighth Amendment.

Reasoning:

The way to determine whether a punishment is cruel and unusual is by looking at whether a punishment was cruel and unusual at the time the Constitution was written, or by looking at the “evolving standards of decency that mark the progress of a maturing society.”  There is no argument about the 18th century definition of cruel and unusual punishment, so the relevant inquiry is the current standards of decency as reflected by objective evidence.

The pattern of federal and state laws does not demonstrate a consensus in the Nation regarding the execution of 16 and 17 year olds.  Specifically, of the 37 states with the death penalty, 15 decline to impose it on 16 year olds, and 12 decline to impose it on 17 year olds.  Further, statistics do not support the notion that there is a demonstrable reluctance of juries to impose capital punishment on 16 and 17 year olds.

Justice Scalia who wrote for the majority, also added with a plurality of Justices that laws that set the legal age at 18 for various activities (such as driving) are not relevant when determining the propriety of capital punishment.  Also, public polls and the positions of various interest groups are not appropriate to provide a foundation for constitutional law.

Concurring and Dissenting Opinions:

Concurring Opinion (O’Connor):

No national consensus forbids executing 16 and 17 year olds.  However, the Court has the obligation to conduct a proportionality analysis, and should consider age-based statutory classifications that are relevant to the analysis.

Dissenting Opinion (Brennan):

Taking the life of someone for a crime he or she committed when they were under 18 is cruel and unusual punishment.  Justice O’Connor is correct that the Court must go beyond the plurality’s assessment of the state of the law in the various states.  Reviewing all age-based statutes and a proportionality analysis are required to truly judge the constitutionality of a death sentence.

Significance:

Stanford v. Kentucky was overruled two years later by the Court decision in Roper v. Simmons that held that it is unconstitutional to execute someone for a crime committed as a juvenile.  Indeed, Justice Brennan’s dissent presages the Roper analysis that juveniles are not entirely responsible for their actions at a young age.  This case, therefore, provides context to the Court’s evolution on the issue of capital punishment for juveniles.  The heinousness of the crimes committed by the juveniles in this case seems to have driven the opinions to some degree.

Student Resources:

Read the Full Court Opinion

Listen to the Oral Arguments

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