Roper v. Simmons
543 U.S. 551 (2005)
Rule of Law:
The Eighth and Fourteenth Amendments to the U.S. Constitution prohibit the imposition of the death penalty on offenders who were under the age of 18 when they committed their crimes.
Facts:
- At age 17, Christopher Simmons planned to commit a burglary and murder.
- Simmons discussed his plan with two younger friends, Charles Benjamin (15) and John Tessmer (16), assuring them they could 'get away with it' because they were minors.
- Simmons and Benjamin broke into the home of Shirley Crook.
- Simmons recognized Mrs. Crook from a previous car accident, which he later stated confirmed his resolve to murder her.
- Simmons and Benjamin bound Mrs. Crook with duct tape and electrical wire, drove her to a state park, and threw her from a railroad trestle into a river, where she drowned.
- Following the murder, Simmons bragged to friends about the killing.
Procedural Posture:
- The State of Missouri charged Christopher Simmons in state trial court with burglary, kidnaping, stealing, and murder in the first degree.
- A jury found Simmons guilty of murder and, after the penalty phase, recommended the death penalty, which the trial court imposed.
- The Missouri Supreme Court affirmed the conviction and sentence on direct appeal.
- Simmons' subsequent motions for state post-conviction relief and his petition for a federal writ of habeas corpus were denied at all levels.
- After the U.S. Supreme Court decided Atkins v. Virginia, Simmons filed a new petition for relief in Missouri state court.
- The Missouri Supreme Court set aside Simmons' death sentence, ruling that a national consensus had developed against executing juvenile offenders since the Court's decision in Stanford v. Kentucky.
- Roper, the Superintendent of the Potosi Correctional Center, sought and was granted a writ of certiorari from the U.S. Supreme Court to review the Missouri Supreme Court's decision.
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Issue:
Does the Eighth Amendment, as applied to the states through the Fourteenth Amendment, prohibit the execution of an offender who was under the age of 18 at the time he committed a capital crime?
Opinions:
Majority - Justice Kennedy
Yes. The Eighth and Fourteenth Amendments forbid the imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed. The Court's analysis rests on the 'evolving standards of decency that mark the progress of a maturing society.' First, objective indicia of national consensus show that 30 states prohibit the juvenile death penalty, its actual use is infrequent, and the trend is consistently toward its abolition. Second, the Court exercises its own independent judgment, concluding that the death penalty is a disproportionate punishment for juveniles. Three general differences between juveniles and adults render juveniles categorically less culpable: 1) a lack of maturity and an underdeveloped sense of responsibility, 2) a greater susceptibility to negative influences and outside pressures, and 3) a character that is more transitory and less well-formed. Because of this diminished culpability, the penological justifications for the death penalty—retribution and deterrence—apply with lesser force to juveniles. This decision overrules Stanford v. Kentucky and finds confirmation in the overwhelming international consensus against the juvenile death penalty.
Concurring - Justice Stevens
I concur. This decision reaffirms the fundamental principle that the Eighth Amendment's meaning is not static but must be interpreted in light of 'evolving standards of decency.' If the Amendment's meaning were frozen in time, it would not prevent the execution of very young children. Our understanding of the Constitution must evolve, and this holding properly reflects that evolution.
Dissenting - Justice O'Connor
No. A categorical rule forbidding the execution of any offender who committed a crime before age 18 is not justified. The objective evidence does not demonstrate a conclusive national consensus against the practice, as it is weaker than in Atkins v. Virginia and several states still legislatively support it. Furthermore, the Court’s moral proportionality analysis is flawed; while adolescents as a class are less mature, it does not mean that no 17-year-old murderer is sufficiently culpable to deserve the death penalty. An individualized sentencing approach, where juries weigh youth as a significant mitigating factor, is the proper constitutional method to account for differences in maturity, rather than an arbitrary, bright-line age rule.
Dissenting - Justice Scalia
No. The Court's decision is based not on law, but on the subjective views of five Justices. The meaning of the Eighth Amendment should be determined by its original understanding, not 'evolving standards of decency.' Even under the majority's flawed test, there is no national consensus against the juvenile death penalty, and counting states that have abolished the death penalty for everyone is illogical. The Court improperly substitutes its own moral judgment for that of the people's elected representatives and inappropriately relies on the laws of foreign countries, which are irrelevant to the interpretation of the U.S. Constitution. This decision undermines the rule of law by proclaiming that the Constitution's meaning has changed in just 15 years.
Analysis:
Roper v. Simmons is a landmark Eighth Amendment case that establishes a categorical prohibition on capital punishment for juvenile offenders under 18. This decision extends the Court's reasoning in Atkins v. Virginia, which barred the execution of the mentally retarded, by creating another protected class of offenders based on diminished culpability. The ruling solidifies the 'evolving standards of decency' doctrine as the primary framework for Eighth Amendment analysis and explicitly overrules the recent precedent of Stanford v. Kentucky. Its significant reliance on international legal norms as 'respected and significant confirmation' for its holding was highly controversial and signaled a potential shift in the Court's willingness to consider global opinion in constitutional interpretation.
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