Atkins v. Virginia
536 U.S. 304 (2002)
Rule of Law:
The execution of mentally retarded criminals constitutes "cruel and unusual punishment" and is prohibited by the Eighth Amendment to the United States Constitution.
Facts:
- On August 16, 1996, Daryl Renard Atkins and his accomplice, William Jones, abducted Eric Nesbitt.
- Atkins and Jones robbed Nesbitt of the money he had on his person.
- They drove Nesbitt in his own truck to an ATM and forced him to withdraw additional cash.
- Atkins and Jones then took Nesbitt to an isolated location where he was shot eight times and killed.
- During the legal proceedings, a forensic psychologist testified that Atkins was "mildly mentally retarded," based on interviews, records, and a standard intelligence test that indicated a full-scale IQ of 59.
Procedural Posture:
- Daryl Renard Atkins was convicted of capital murder in a Virginia trial court, and the jury sentenced him to death.
- On direct appeal, the Supreme Court of Virginia affirmed the conviction but ordered a second sentencing hearing because the trial court had used a misleading verdict form.
- At the resentencing hearing, a new jury again sentenced Atkins to death.
- The Supreme Court of Virginia affirmed the imposition of the death penalty, rejecting Atkins's argument that he could not be executed because he is mentally retarded.
- The United States Supreme Court granted certiorari to reconsider the issue of whether executing the mentally retarded violates the Eighth Amendment.
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Issue:
Does the execution of a mentally retarded criminal violate the Eighth Amendment's prohibition against cruel and unusual punishments?
Opinions:
Majority - Justice Stevens
Yes. The execution of mentally retarded criminals is a cruel and unusual punishment prohibited by the Eighth Amendment. The Court's interpretation of the Eighth Amendment is guided by the "evolving standards of decency that mark the progress of a maturing society." The primary objective evidence of these standards is legislation enacted by state legislatures. Since the Court's 1989 decision in Penry v. Lynaugh, a significant number of states have passed laws prohibiting the execution of mentally retarded individuals, demonstrating a national consensus against the practice. The Court's independent judgment aligns with this consensus because the penological goals of the death penalty—retribution and deterrence—are not advanced by executing the mentally retarded. Their diminished culpability makes the ultimate retribution less appropriate, and their cognitive impairments make them less likely to be deterred by the possibility of execution. Furthermore, these defendants face a special risk of wrongful execution due to their heightened vulnerability in the legal process.
Dissenting - Chief Justice Rehnquist
No. The execution of mentally retarded criminals does not violate the Eighth Amendment's prohibition against cruel and unusual punishment. The Court's claim of a "national consensus" is flawed, as fewer than half of the states permitting capital punishment had banned the practice. The Court improperly relies on subjective and irrelevant sources such as foreign laws, the views of professional organizations, and opinion polls to determine American standards of decency. The only objective indicia should be legislative enactments and the actions of sentencing juries, which do not support a categorical ban. This decision oversteps judicial authority and undermines principles of federalism by preventing states from making individualized determinations of culpability and punishment in capital cases.
Dissenting - Justice Scalia
No. The execution of mentally retarded criminals does not violate the Eighth Amendment. The Court's decision has no foundation in the text or original history of the Eighth Amendment and rests instead on the subjective moral preferences of its members. The finding of a "national consensus" is fabricated from the recent actions of a minority of death-penalty states. Juries are fully capable of weighing mental retardation as a mitigating factor against the brutality of a particular crime, as the Virginia jury did in this case. The Court's reasoning regarding the penological goals of retribution and deterrence is flawed, as a jury could reasonably conclude that a mentally retarded offender who commits a heinous crime is sufficiently culpable to deserve the death penalty. This ruling creates a categorical rule that undermines the traditional role of the jury and invites defendants to feign mental retardation to escape justice.
Analysis:
Atkins v. Virginia is a landmark Eighth Amendment decision that established a new categorical protection, reversing the Court's prior holding in Penry v. Lynaugh. The ruling cemented the doctrine of "evolving standards of decency" as a key principle of Eighth Amendment jurisprudence, heavily relying on legislative trends as the primary evidence of a national consensus. This case transformed the issue of a capital defendant's mental retardation from a mitigating factor for a jury to consider into a complete constitutional bar to execution. Consequently, the decision required states to develop procedures for determining whether a defendant meets the criteria for mental retardation, shifting the legal landscape for capital punishment.
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