Roper v. Simmons
161 L. Ed. 2d 1 · Supreme Court of the United States · 2005
Facts
At the age of 17, Christopher Simmons, a junior in high school, committed murder. He planned the crime with two friends, discussing his intent to murder someone by breaking and entering, tying up a victim, and throwing them off a bridge, assuring his friends they could 'get away with it' as minors. Simmons and one friend entered Shirley Crook's home, tied her with duct tape, put her in her minivan, and drove her to a state park. There, they reinforced her bindings, covered her head, and threw her from a railroad trestle into the Meramec River, causing her to drown. Simmons later bragged about the killing, telling friends he had killed a woman 'because the bitch seen my face.' Police arrested Simmons, read him his Miranda rights, and he confessed to the murder after less than two hours of interrogation.
Procedural history
Christopher Simmons was tried as an adult and sentenced to death for a murder committed at age 17. The Missouri Supreme Court affirmed his conviction and sentence, and federal courts denied his habeas corpus petition. After this Court held in Atkins v. Virginia that executing mentally retarded persons was unconstitutional, Simmons filed a new state postconviction petition. The Missouri Supreme Court agreed with Simmons, setting aside his death sentence and resentencing him to life imprisonment, leading to this Court granting certiorari.
Issue
Whether it is permissible under the Eighth and Fourteenth Amendments to the Constitution of the United States to execute a juvenile offender who was older than 15 but younger than 18 when he committed a capital crime.
Holding
The Eighth and Fourteenth Amendments forbid imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed. The judgment of the Missouri Supreme Court setting aside the sentence of death imposed upon Christopher Simmons is affirmed.
Rule
The Eighth Amendment, applicable to the States through the Fourteenth Amendment, prohibits cruel and unusual punishments, which are determined by 'evolving standards of decency that mark the progress of a maturing society.' This requires reviewing objective indicia of consensus, such as legislative enactments and state practice, and the Court's independent judgment on proportionality. Juveniles under 18 cannot reliably be classified among the worst offenders due to their lack of maturity, susceptibility to negative influences, and less formed character, making their culpability diminished. Therefore, the penological justifications of retribution and deterrence apply with lesser force to juveniles, making the death penalty a disproportionate punishment for this class of offenders.
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