Roper v. Simmons

543 U.S. 551 (2005)

Facts and Procedural History:

At the age of 17, Simmons planned and committed a capital murder. After he had turned 18, he was sentenced to death. His direct appeal and subsequent petitions for state and federal post-conviction relief were rejected. Simmons filed a new petition for state post- conviction relief, arguing that Atkins reasoning established that the Constitution prohibits the execution of a juvenile who was under 18 when he committed his crime. The Missouri Supreme Court agreed and set aside Simmons' death sentence in favor of life imprisonment without eligibility for release.

Issue Presented to the Court:

Is it permissible under the Eighth and Fourteenth Amendments to execute a juvenile offender who was older than 15 but younger than 18 when he committed a capital crime?

Outcome of the Case:

The Court held that 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 “evolving standards of decency” in the interpretation of the Eighth Amendment required the Court to determine a national consensus against the death penalty for juveniles. It concluded that as in Atkins the objective indicia of consensus -the rejection of the juvenile death penalty in the majority of States ; the infrequency of its use even where it remains on the books; and the consistency in the trend toward abolition of the practice-provide sufficient evidence that today our society views juveniles as "categorically less culpable than the average criminal." Three general differences between juveniles under 18 and adults demonstrate that juvenile offenders cannot be classified among the worst offenders. (1) Juveniles are less morally reprehensible as adults due to their to immature and irresponsible behavior (2) Because of their own vulnerability and comparative lack of control juveniles have a greater claim than adults to be forgiven for failing to escape negative influences in their environment. (3) The reality that juveniles still struggle to define their identity means it is less supportable to conclude that even a heinous crime committed by a juvenile is evidence of irretrievably depraved character.

The Court concluded that determination that the death penalty is disproportionate punishment for offenders under 18 finds confirmation in the “stark reality that the United States is the only country in the world that continues to give official sanction to the juvenile death penalty”. Although this international opinion is not controlling, it provides respected and significant confirmation for the Court's determination that the penalty is disproportionate punishment for offenders under 18.