Roper v. Simmons: Difference between revisions

{{SCOTUSCase|Litigants=Roper v. Simmons |ArgueDate=October 13|ArgueYear=2004 |DecideDate=March 1|DecideYear=2005|USVol=543 |USPage=551|Docket=03-633|OralArgument=http://www.oyez.org/cases/2000-2009/2004/2004_03_633/argument|Citation=125 S. Ct. 1183; 161 L. Ed. 2d 1; 2005 U.S. LEXIS 2200; 73 U.S.L.W. 4153; 18 Fla. L. Weekly Fed. S 131 |Prior=Defendant convicted, motion for postconviction relief denied, [[Missouri Circuit Courts|Circuit Court of Jefferson County, Missouri]]; affirmed, 944 S.W. 2d 165 (Mo. 1997) (en banc), certiorari denied, 522 U.S. 953 (1997). Denial of petition for a writ of habeas corpus affirmed, 235 F. 3d 1124 (CA8), certiorari denied, 534 U. S. 924 (2001). Petition for a writ of habeas corpus granted, 112 S.W. 3d 397 (Mo. 2003) (en banc), certiorari granted, 540 U.S. 1160 (2004) |Subsequent=|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. Supreme Court of Missouri affirmed, and [[Stanford v. Kentucky]] overturned. |SCOTUS=1994-2005|Majority=Kennedy|JoinMajority=Stevens, Souter, Ginsburg, Breyer|Concurrence=Stevens|JoinConcurrence=Ginsburg |Dissent=O'Connor|Dissent2=Scalia|JoinDissent2=Rehnquist, Thomas|LawsApplied=[[Eighth Amendment to the United States Constitution|U.S. Const. amends. VIII]], [[Fourteenth Amendment to the United States Constitution|XIV]]}}

 

 

== The case ==

Once the case went to trial, the [[evidence (law)|evidence]] was overwhelming. Simmons had confessed to the murder, performed a videotaped reenactment at the crime scene, and there was testimony from Tessmer against him that showed [[premeditation]] (he discussed the plot in advance and later bragged about the crime). The jury returned a guilty verdict. Even considering [[mitigating factor]]s (no criminal history and his age), <!-- sympathy from Simmons' family NOTE: "sympathy from Simmons' family" or "sympathy for Simmons family"?? --> the jury recommended a death sentence, which the trial court imposed. Simmons first moved for the trial court to set aside the conviction and sentence, citing, in part, ineffective assistance of counsel. His age, and thus impulsiveness, along with a troubled background were brought up as issues that Simmons claimed should have been raised at the sentencing phase. The trial court rejected the motion, and Simmons appealed.

 

 

The State of Missouri appealed the decision to the U.S. Supreme Court, which agreed to hear the case. (Donald P. Roper, the Superintendent of the correctional facility where Simmons was held, was a party to the action because it was brought as a petition for a writ of [[habeas corpus]].)

This case was argued on October 13, 2004. The appeal challenged the constitutionality of capital punishment for persons who were juveniles when their crimes were committed, citing the [[Eighth Amendment to the United States Constitution|Eighth Amendment]] protection against [[cruel and unusual punishment]].

 

 

Under the "evolving standards of decency" test, the Court held that it was cruel and unusual punishment to execute a person who was under the age of 18 at the time of the murder. Writing for the majority, [[Anthony Kennedy|Justice Kennedy]] cited a body of sociological and scientific research {{ref|research}} that found that juveniles have a lack of maturity and sense of responsibility compared to adults. Adolescents were found to be overrepresented statistically in virtually every category of reckless behavior. The Court noted that in recognition of the comparative immaturity and irresponsibility of juveniles, almost every state prohibited those under age 18 from voting, serving on juries, or marrying without parental consent. The studies also found that juveniles are also more vulnerable to negative influences and outside pressures, including peer pressure. They have less control, or experience with control, over their own environment. They also lack the freedom that adults have, in escaping a criminogenic setting.<ref>See {{Citation |last=Steinberg |first=Laurence |lastauthoramp=yes |last2=Scott |first2=Elizabeth S. |title=Less Guilty by Reason of Adolescence: Developmental Immaturity, Diminished Responsibility, and the Juvenile Death Penalty |journal=American Psychologist |volume=58 |issue=12 |pages=1009–1018 [p. 1014] |year=2003 |doi=10.1037/0003-066X.58.12.1009 |pmid=14664689 }}.</ref>