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- Atkins v. Virginia (2002)
- The issue centered on the question of whom or which types of defendants can be executed, relating to Individuals with an Intellectual Disability (IID)
- According to Atkins’ forensic psychologist, his IQ score was 59—well below the average IQ score of 100
- The Court ruled that executing the “mentally retarded” is excessive, cruel and unusual punishment, and is not permitted by the constitution
- The evolving standards of decency standard was of great importance in the decision
- Atkins is a significant case because it categorically exempts a certain class of people from receiving the death penalty—Individuals with Intellectual Disabilities
- Additional Cases of Interest:
- Penry v. Lynaugh (1989): The Court upheld the practice of executing “mentally retarded” persons (IID) who have the ability to reason
- Panetti v. Quarterman (2007): A defendant must understand a state’s reasoning for executing him/her
- Hall v. Florida (2014): The Court ruled that Florida’s rule that prevented capital defendants with an IQ over 70 to present other evidence of an intellectual disability was too rigid and violated the 8th and 14th Amendments
- Ring v Arizona (2002)
- The issue in this case was the 6th Amendment’s guarantee of a defendant’s right to a jury trial
- The Court ruled that only a jury can decide whether or not to sentence a defendant to death, not a judge
- In a 6-2 ruling, the justices pointed out that it would be a mistake to take the power away from juries
- The Ring decision diminished the power of judicial discretion in capital cases
- Additional Cases of Interest:
- In Walton v. Arizona, 497 U.S. 639 (1990): The Court ruled trial judges have complete sentencing authority in capital cases
- Apprendi v. New Jersey (2000): The Court ruled that only juries can make determinations of facts that lead to an increase in severity of a defendant’s sentence
- Roper v. Simmons (2005)
- Revisited the issue of executing juveniles
- In a 5-4 ruling, it was forbidden to impose the death penalty on offenders less than 18 years of age
- The Court considered the evolving standards of decency and found the majority of states already rejected the juvenile death penalty
- The Court set forth three differences between juvenile and adult offenders: First, since juveniles are immature and irresponsible and their conduct is not as morally reprehensible as adults; second, juveniles are impressionable and susceptible to peer pressure; third, juveniles suffer from identity crises and it does not mean their character is irretrievably depraved
- Additional Cases of Interest
- Thompson v. Oklahoma (1988): Court ruled it is unconstitutional to execute 15 year-olds
- Stanford v. Kentucky (1989): Court ruled 16 and 17 year-olds can receive the death penalty (see chapter 3)
- Baze and Bowling v. Reez (2008)
- Ralph Baze and Thomas Bowling were two Kentuckians convicted of murder and sentenced to death
- The men challenged their executions arguing that the three-drug protocol has the potential to result in “unnecessary pain and suffering”
- The three drugs used in Kentucky were: Sodium Thiopental, Pancuronium Bromide and Potassium Chloride. The first drug is an anesthetic and is meant to induce unconsciousness so that the offender does not feel the painful effects of the second and third drugs. The second drug causes paralysis and the third drug induces cardiac arrest
- The issue was that death by lethal injection is cruel and unusual punishment
- In a 7-2 vote, the Court ruled that administration of the three-drug protocol does not amount to cruel and unusual punishment because it does not “create a substantial risk of wanton and unnecessary infliction of pain, torture, or lingering death”
- Additional Cases of Interest:
- Wilkerson v. Utah (1879): Firing squad is a constitutional method of execution
- In re Kemmler (1890): Death by electrocution is a constitutional method of execution