Roper v Simmons - Procedural History - Essay Example

The trial court found no constitutional violation and denied the motion. Simmons’ subsequent appeals were denied at all levels.

After Simmons’ had exhausted all appeals, the Supreme Court ruled in another case that the Eighth and Fourteenth Amendments prohibit the execution of a mentally retarded person (Atkins v. Virginia, 536 U.S. 302 (2002)). When Simmons became aware of this ruling, he submitted a petition for a writ of habeas corpus and requested post-conviction relief based on the assertion that the reasoning of Atkins established a Constitutional protection against the death penalty for a convicted individual who was a minor when the crime was committed. The Supreme Court of Missouri agreed with Simmons and Roper (on behalf of the State of Missouri) and appealed to the United States Supreme Court.

Facts

At 17 years of age, Christopher Simmons discussed the idea of murdering someone as a “prank” with some friends. He reasoned that they would not get caught and if they were, they were juveniles and there would be little consequence. At 2:00 AM on the morning of the murder, he and his accomplice broke into the house of Shirley Crook. They used duct tape to cover her eyes, mouth, and hands and put her in her minivan. They then drove to a state park, covered her head with a towel, and walked her to a railroad trestle spanning the Meramec River. At that point they, they tied her hands and feet with electrical wire, covered her entire face in duct tape, and threw her into the water.
Approximately nine months later, at the age of 18, Simmons was convicted of first-degree murder and sentenced to death. His case was taken by the Supreme Court on the question of the constitutionality of applying the death penalty to criminals who were juveniles when their crime was committed.

Issue
Do the Eighth and Fourteenth Amendments to the Constitution prevent the death penalty in cases where the convicted person is under the age of 18 years old?
Answer
Yes. Executing convicted felons whose crimes were committed before they turned 18 years old is a violation of the cruel and unusual punishment clause of the Eighth Amendment as well as the equal protection clause of the Fourteenth Amendment.

Reasoning
The Court recognizes the Eighth Amendment’s preclusion of cruel and unusual punishment, and has established the propriety of referring to “’ the evolving standards of decency that mark the progress of a maturing society’ to determine which punishments are so disproportionate as to be cruel and unusual.” The court, in Atkins v. Virginia, 536 U.S. 302 (2002)), had determined that executing mentally retarded persons were cruel and unusual and that this case involved a similar principle of evaluating the jurisprudence of the states to poll society’s position. The court also mentioned the international standards of conduct, including the fact that the United States was one of a handful of countries that executed juvenile offenders (a reference that prompted a particularly scathing dissent from Justice Scalia). Under the “evolving standards” doctrine, the court reasoned that society had now come to regard the execution of juvenile offenders to be cruel and unusual.

Holding

The Court affirmed the ruling by the Supreme Court of the State of Missouri that Simmons could not be sentenced to death for a crime he committed as a minor. Read More