Juvenile Death Penalty Case Study

The punishment of juveniles by execution is a longstanding practice in our nation’s history. Throughout the last few decades, the U.S. Supreme court has been asked to determine if the execution of a juvenile, sixteen or seventeen years old at the time of the offense, represents cruel and unusual punishment. In various rulings, the U.S. Supreme court has interpreted cruel and unusual punishment to include penalties that are excessive, not proportioned to the offense, and those that do not consider the defendant’s degree of criminal culpability. One case in particular that addresses the death penalty as cruel and unusual punishment for juveniles is the landmark court case Roper v. Simmons.

The background facts of the case began in 1993, when

17 year old Christopher Simmons, committed murder. Simmons, who was a junior in high school at the time, discussed with his friends his infatuation to kill someone by breaking into and entering the person’s home, robbing the person, tying the person up, and then throwing the person off of a bridge (Scott, 2005). He told his friends that he could get away with the murder because he was a minor. Regrettably, on September 9, 1993, Simmons and one of his younger male friends met around 2:00 a.m. and proceeded to the home of Mrs. Shirley Crook. Simmons reached through the window of her back door, unlocked it and they proceeded to enter her home. Mrs. Crook was then awakened and asked who was there. Simmons continued to Mrs. Crook’s bedroom and remembered seeing her after a car accident, in which they were both involved (Scott, 2005). This led Simmons to be concerned about Mrs. Crook recognizing him, which caused him to be more determined to kill her. As a result, Simmons and his friend used duct tape to secure Mrs. Crook’s hands, and to cover her mouth and eyes. They then put Mrs. Crook into her minivan and drove to a local state park. Upon arrival to the park, Simmons and his friend came across a railroad trestle bridge that linked across the Meramec River. Simmons and his friend then used electrical wire to secure Mrs. Crook’s hands and feet together (Scott, 2005). They also wrapped her entire face with duct tape, and then threw her into a nearby river where she drowned. After the incident, Simmons was overheard telling his friends that he had killed Mrs. Crook because she had seen his face. Later that same afternoon, a fisherman found Mrs. Crook’s dead body in the river. The following day, the police arrested Simmons for the alleged offense. In turn Simmons waived his Miranda rights and confessed to the murder. Simmons was tried and convicted as an adult for first degree murder (Scott, 2005).

At the sentencing stage, the State presented aggravating factors calling attention to the fact that he had murdered Mrs.

Crook to prevent his arrest, combined with the brutal, inhumane nature of the killing that followed a botched burglary. In response, Simmons defense counsel emphasized his lack of any prior charges or convictions and his close, loving relationship with family members (Scott, 2005). His defense counsel also asked the jury to consider Simmons age as a mitigating factor, noting that juveniles were not legally allowed to drink, serve on a jury, or see certain movies because they were not considered old enough to assume those responsibilities. With all things considered, the jury recommended the death sentence, which was imposed by the judge (Scott, 2005). Unhappy with the ruling in his case, Simmons appealed his conviction, arguing that he had received inadequate assistance of counsel because additional information regarding his difficult home background, impulsivity, and susceptibility to being easily influenced by others were not adequately presented at the sentencing hearing. Simmons petition for postconviction relief was denied by the trial court, and affirmed by the Supreme Court of Missouri (Scott, 2005). In 2001, Simmons petitioned for writ of habeas corpus, which was also denied by the federal courts. In the following year, Simmons submitted a new petition for postconviction relief arguing that the Supreme Court’s reasoning for prohibiting the imposition of the death penalty on those declared with mental retardation should also be applied to juveniles (Scott, 2005). Simmons argued this because the U.S. Supreme Court ruled in Atkins v. Virginia, that the execution of a person with mental retardation was prohibited by the Eighth and Fourteenth Amendments of the Constitution. The Missouri Supreme Court agreed with Simmons based on the U.S. Supreme Court’s prior ruling in Stanford, which lead to the development of a national consensus against

the execution of juvenile offenders. Consequently, the Supreme Court of Missouri overturned Simmons’ death sentence and resentenced him to life imprisonment without the possibility of parole (Scott, 2005).

This court case eventually made its way to the U.S. Supreme Court, who granted certiorari to determine if the imposition of the death penalty on a juvenile who commits a capital offense is cruel and unusual punishment, which is barred by the Eighth and Fourteenth Amendments. Ultimately, this was the issue of the case (Scott, 2005). Arguably, in a five to four decision, the U.S. Supreme Court confirmed the judgement of the Missouri Supreme Court and held that the Eighth and Fourteenth Amendments of the U.S. Constitution forbid the imposition of the death penalty on a juvenile offender who was younger than eighteen and older than fifteen when the capital crime was committed (Scott, 2005).

Reference

Scott, C.L. (2005). Roper v. Simmons: Can Juvenile Offenders be Executed? The Journal of the American Academy of Psychiatry and the Law. 33 (4) 547-552. Retrieved from http://jaapl.org/content/jaapl/33/4/547.full.pdf.