Stanfod v. Kentucky

492 U.S. 361 (1989)

Facts and Procedural History:

A defendant who was approximately 17 years and 4 months old at the time he committed a murder in Kentucky was convicted of murder, sodomy, robbery and receiving stolen property and was sentenced to death. In another case, a defendant who was approximately 16 years and 6 months old when he committed a murder in Missouri was certified for trial as an adult and sentenced to death. The Supreme Court granted certiorari for both cases.

Issue Presented to the Court:

Does the imposition of capital punishment on an individual for a crime committed at 16 or 17 years of age constitute cruel and unusual punishment under the Eighth Amendment?

Outcome of the Case:

The Court affirmed, rejecting the contention that the sentences violated the Eighth Amendment.

First, in determining whether a punishment violates evolving standards of decency, petitioners failed to prove a settled national consensus against the execution of 16- and 17-year-old offenders. Of the 37 States that permit capital punishment, 15 decline to impose it on 16-year-olds and 12 on 17-year-olds.

Second, there is no support for petitioners' argument that a demonstrable reluctance of juries to impose, and prosecutors to seek, capital sentences for 16- and 17-year-olds establishes a societal consensus that such sentences are inappropriate.

Next, the Court rejected the argument that the laws cited by petitioners and their amici which set 18 or more as the legal age for engaging in various activities, ranging from driving to drinking alcoholic beverages to voting are of any relevance to this case. According to the Court, “it is absurd to think that one must be mature enough to drive carefully, to drink responsibly, or to vote intelligently in order to be mature enough to understand that murdering another human being is profoundly wrong, and to conform one's conduct to that most minimal of all civilized standards”.

Finally, the Court also rejected petitioners' argument that capital punishment of 16- and 17-year-old offenders should be invalidated on the ground that it does not serve the goal of deterrence because juveniles, possessing less developed cognitive skills than adults, are less likely to fear death; and it fails to exact just retribution because juveniles, being less mature and responsible, are also less morally blameworthy.