Penry V. Lynaugh Case Study

These decisions led to a partial striking down of Texas’s capital punishment statute in 1989. The Supreme Court held that the question of whether a defendant would be a “future danger” to the community did not adequately allow for consideration of the defendant’s mental retardation as a possible mitigating factor. (Penry v. Lynaugh). Some jurors might believe that a defendant like Johnny Penry with a low IQ might be more likely to commit future crimes, perhaps because he could not learn from his mistakes or be deterred by the law. That ruling forced Texas to change the way juries were instructed in death penalty cases. Juries needed to understand that a person’s mental retardation should at least be considered as reason for giving him a life sentence.

Gary Graham’s lawyers believed that the same reasoning should apply to a defendant’s youth.

They took their case all the way to the Supreme Court, but were told that the ruling in Penry did not apply to Graham because it was not retroactive, i.e., it would only apply to future cases. (Graham v. Collins). In a later ruling, the Court held that even in a case where Penry did apply, a defendant’s youth is not the same as a defendant’s mental retardation. Texas’ law did not have to change to give special consideration to the age of the defendant. (Johnson v. Texas). Ultimately, the Court struck down the death penalty for both juveniles and the mentally retarded. (Roper v. Simmons; Atkins v.

Virginia).
State law in Illinois requires a mandatory life sentence for any defendant convicted of killing more than one person (even if convicted as an accomplice). The Illinois Supreme Court has not, as yet, addressed the constitutionality of the sentencing law as applied to juveniles convicted as accomplices in murder trials (Hanna, 2000).

Conclusion
Unfortunately, individuals who were juveniles at the time they committed a capital offense continue to be sentenced to the death penalty in the United States. Although the number of juvenile offenders affected by the death penalty is small, these offenders serve as a focal point for often highly politicized debates about the constitutionality of the death penalty, public safety, alternatives available to judges and juries in determining the fates of these youth, and, most crucial, the effectiveness of the juvenile justice system in safeguarding the due process rights of youth.