The Impact of Roper v. Simmons

The death penalty is utilized by the United States to punish offenders who have committed heinous violent crimes, to attain leverage and extract confessions or information from offenders, and to provide a deterrent that discourages other members of society from committing similar crimes. However, many American citizens oppose the use of the death penalty by contending that the punishment is excessively vicious. Opponents also emphasize that many initial murder convictions have been later reversed because new information derived from innovative technological resources proved the innocence of people who juries had previously and mistakenly convicted as guilty. For a state to execute a person who later is proved to be entirely innocent reflects a reprehensible mistake by society, for the execution kills an innocent life, wastes the talents of a valuable member of society, and impairs the atmosphere of the community. Thus, there are many sound arguments and valid reasons to support capital punishment or to oppose the use of the death penalty as a punishment. One of the biggest controversies surrounding the contentious issue of capital punishment is the debate regarding whether juveniles should qualify for the death penalty. The United States Supreme Court decision of Roper v. Simmons was a pivotal ruling that had a significant influence on the nature of the juvenile justice system in America by establishing standards for the prosecution of violent juvenile crimes, determining the age requirements for death penalty eligibility, and by prohibiting the execution of juveniles.

Throughout its history, the United States has been evaluating and assessing the best possible methods of punishing and deterring juvenile crimes. However, during the 1960s the crime rates in the country surged to excessive levels, and the high crime rates encouraged the government to diligently attempt to provide states with the advanced resources required to control and minimize crime. The government also began to seriously address the issue of juvenile crime by providing states with financial grants and beneficial programs to help prevent juveniles from succumbing to criminal behavior and to determine consequences for juveniles that do commit crimes. The government also established the juvenile justice system in which youths would be tried for violations. A conflict of the juvenile justice system was that states were able to determine what age limit provided the line between juveniles and adults, with the specific age varying depending on the particular state. Additionally, provisions were implemented to assert that juveniles who committed serious violent crimes were automatically eligible to be tried as adults and in a standard court, regardless of the age of the juvenile (Schmalleger). Occasionally the American society experiences the shock of learning that young children have committed brutally violent and stunningly egregious crimes to harm other people, and when these instances periodically occur the citizens and legislators of our society often must debate whether the crimes warrant capital punishment. In capital punishment states, because adults on trial in the standard court system are eligible for the death penalty, trying a juvenile who has committed a violent crime as an adult spawned inevitable debates about juvenile death penalty sentences.

In 2005, the consequential US Supreme Court decision of Roper v. Simmons had a dramatic impact on the juvenile justice system and on the issue of the death penalty. In 1993, a 17-year-old boy named Christopher Simmons concocted a thorough plan to attack another girl at night. Although Simmons initially conspired with two other friends, one friend withdrew from the plot, and thus Simmons implemented the plan with one other friend. One night Simmons and his friend broke in and entered the home of the targeted female victim, robbed her of various possessions, tied her hands with an electrical cord, bound her body with duct tape, and then stuffed her mouth to prevent screaming. After the invasion and robbery processes were complete, Simmons and his friend then brought the victim to a local park, threw her over a bridge, and left her dead body to rot in a river (Roper v. Simmons, Casebriefs). Compelling evidence quickly led the detectives to Simmons, including reports that the teenager was consistently bragging about the murder. Thus, Simmons confessed to the crime when he was brought into custody, at which point he was tried as an adult, convicted of the murder and sentenced to death.

A complicated aspect of the death penalty sentence was the specific age of the defendant. Although Simmons was 18 years old when the sentence was issued, he was only 17 years old when he actually committed the crime. Because age requirements for the legal system of Missouri established juveniles as being offenders who were under the age of 18 during the crime, Simmons was technically considered as a juvenile, which instigated a contentious dispute regarding whether it was permissible or constitutional for the state to execute Simmons despite his status as a juvenile. As a result of the controversial death penalty sentence, Simmons appealed the sentence. After the state and federal appeals were both denied, in 2002 Simmons appealed to the Missouri Supreme Court, and the State Supreme Court reversed the capital punishment sentence as a violation of the 8th amendment (Roper v. Simmons, Chicago-Kent). Roper, the lead prosecutor of the case, responded to the reversal by bringing the case to the US Supreme Court, citing that it was illegitimate and potentially dangerous for the state court to overrule a decision made by the federal appellate court.

The 8th amendment was a significant focus of the Roper v. Simmons Supreme Court case. The 8th amendment prohibits any state from utilizing methods of cruel and unusual punishment on any offenders, which in turn generates disputes regarding how the amendment should be interpreted and what constitutes cruel and unusual punishment. The case was also influenced by a previous case that the Supreme Court had recently ruled on in 2002, the case of Atkins v. Virginia. In this case, in which a mentally disabled person committed murder, the Court ruled that executing a mentally challenged individual represents cruel and unusual punishment because the mind of the individual is disadvantaged and lacks full development. Because the Court ruled that it was a violation of the 8th amendment to execute a mentally disabled person whose mind is not fully developed, the Simmons legal team used this as precedence and argued that the Court must also rule that executing a child whose mind has not fully developed also represents cruel and unusual punishment (Roper v Simmons, UMKC). In contrast, Roper’s prosecution team argued that capital punishment for egregiously intolerable crimes is not cruel and unusual, the excessively vicious nature of the well-planned crime qualified Simmons for the maximum punishment, the legal precedence of Stanford v. Kentucky establishes that juveniles can receive the death penalty, and providing the maximum penalty can prevent other juveniles from resorting to similar violent behavior.

In 2005, the US Supreme Court delivered the influential landmark decision by ruling in favor of Simmons and by asserting that the use of capital punishment on a juvenile is officially an unconstitutional violation of the 8th amendment. The majority opinion of the decision was delivered by Justice Kennedy, and Justice Kennedy elaborated on many arguments to support the ruling. For instance, Kennedy establishes three primary differences that distinguish the classifications of juveniles from adults. One difference is that the crimes of juveniles cannot be considered as morally reprehensible as crimes committed by adults because juveniles are young, ignorant and inexperienced. These characteristics of youth make juveniles comparably more susceptible to engage in immature and irresponsible behavior in which they act on impulse and display a lack of understanding regarding consequences (Roper v. Simmons, Cornell). In contrast, adults possess the advanced knowledge and essential experience required to control their actions, demonstrate responsible behavior, and comprehend the consequences for their actions. Because the crimes of juveniles are not as reprehensible as crimes of adults, juveniles cannot be held to the same accountability nor suffer the same maximum punishment as adult offenders.

The environment is the second reason why Justice Kennedy and the Supreme Court distinguished juvenile criminals from adult criminals. Juveniles have very minimal control over their surroundings and the environments into which they are born and raised, and thus youths are vulnerable to become influenced by negative circumstances and to be encouraged to commit delinquent behavior by their peers. In contrast, adults have more control over the environment that they immerse themselves into and more control over their ability to resist negative influences that might encourage criminal behavior (Denno). Children are much more vulnerable to be manipulated by negative environments that facilitate delinquent behavior than adults, and thus the violent crimes committed by juveniles are more forgivable than the crimes of adults.

The third distinction Justice Kennedy establishes between juvenile and adult criminals is that juveniles have not fully developed. Similar to the Atkins mental disability ruling, juveniles are still undergoing the process of developing their minds, forming their personalities and establishing their identities. Whereas the identities of adult criminals have already been established, juveniles are still developing and are in turn more likely to undergo transformations and be rehabilitated as they mature into the future. In contrast to adults, violent crimes committed by juveniles do not demonstrate an irretrievably depraved character in which the harmful attitudes and destructive behavior of the offender are utterly hopeless to be transformed (Holsinger). Because the minds and personalities of juveniles are still developing, the hope for rehabilitation is more realistic, juveniles are less culpable for their horrendous actions, and thus juveniles cannot be subjected to the same maximum penalty of capital punishment that adult criminals are subjected to. Kennedy utilizes the three distinctions to support the Court’s decision. Compared to adults, juveniles are not as accountable for their crimes because they are susceptible to act irresponsibly, vulnerable to become influenced by negative environments, and still developing their identity. As a result, Kennedy concludes that the juvenile death penalty violates the 8th amendment as an illegal form of cruel and unusual punishment.

The decision delivered by Justice Kennedy also cited public opinion and national trends to support the ruling that using capital punishment on juveniles is unconstitutional. At the time of the 2005 ruling, the trajectory of the US indicated that citizens were growing increasingly opposed to juvenile death sentences and that states were implementing such forms of punishment on juveniles at a much less frequent rate in the past. For instance, Kennedy mentioned that 30 states had already prohibited the juvenile death penalty. Of those 30 states, 12 had officially passed legislation to forbid the death penalty entirely, and the other 18 states still permitted capital punishment but restricted the use of the death penalty on juveniles. Although the remaining 20 states allowed the use of capital punishment on juveniles, Kennedy notes that these states inflict the juvenile death penalty at an extremely minimal and infrequent rate. Additionally, Kennedy remarked that the US was the only country in the world that officially sanctioned the execution of juvenile offenders and that the international opinion consistently criticizes the juvenile death penalty as a disproportionate form of cruel and unusual punishment. While our Supreme Court is not accountable to other countries, the consensus of international opinion enhanced the validity of the Court’s decision to establish the juvenile death penalty as an unconstitutional violation of the constitution. Therefore, Kennedy asserts the common disapproval of the juvenile death penalty among citizens, states and international communities to support the Court’s Roper v. Simmons decision.

The opinion of Kennedy also referred to precedence regarding previous court rulings that concentrated on the 8th amendment or on the juvenile death penalty issue. For example, the case of Trop v. Dulles established standards regarding what constitutes cruel and punishments, which Kennedy applies to the Simmons case to demonstrate that the juvenile death penalty does violate the 8th amendment. Kennedy also cites Thompson v. Oklahoma, which determined that the national standards of decency require that society prohibit the execution of any offenders who are less than 16 years of age during the time in which the crimes were committed (Roper v. Simmons, Cornell). Additionally, Kennedy naturally refers to the Atkins case in which the Court forbids the application of the death penalty on mentally disabled individuals to support the notion that the penalty should also be restricted from use on juveniles.

However, a significant obstacle that needed to be addressed in the Roper v. Simmons decision was an older case known as Stanford v. Kentucky. In this 1989 case, a 17-year-old named Kevin Stanford conducted an egregious crime in which he and a friend robbed a gas station, brutally raped the female attendant at the station, drove her to an isolated area, and then Stanford shot her in the head. The heinous nature of the crime accompanied by a record of delinquent behavior encouraged the state of Kentucky to prosecute Stanford as an adult, at which point he was convicted and sentenced to death. Despite several appeals by Stanford to reverse the decision, in 1989 the US Supreme Court ruled that it was officially permissible for states to exercise the death penalty on any juvenile at least 16 years of age during the commission of the crime (Dalton). Thus, the Stanford decision became binding and was used as a precedent to justify the use of the death penalty on juveniles in the succeeding decades.

The 2005 Roper v. Simmons ruling was consequential because the decision completely eradicated the precedence set by Stanford and instead established a new precedent. Kennedy disagreed with the Stanford ruling, determined that juvenile death penalty executions violated the 8th amendment by exemplifying cruel and unusual punishment, and declared that the Stanford ruling should no longer be a controlling force of precedence regarding the issue. Kennedy also established 18 as the official age that marks the transition from childhood to adulthood. Although the age of 18 is an arbitrary and objectionable boundary, all categorization laws and age requirement provisions are based on arbitrary foundations, including drinking, smoking, military, and driving age requirements. However, the legislation of the US government and the common perception of the American culture generally identify 18 years old as the transitional age in which a teenager can be considered an adult. Thus, the Court officially determined that the death penalty can only be used on adult criminals who are at least 18 years old.

This new precedent established by the Supreme Court had a powerful influence on the juvenile criminal justice system. The decision officially prohibited all states from applying the death penalty on juveniles and established the age of 18 as the official standard by which an offender can be considered an adult or qualify for capital punishment. Before the ruling, many different states had developed different standards for the juvenile death penalty age limit, with some states opting to execute 16 and 17-year-olds who had committed vicious crimes. However, the Roper v. Simmons ruling immediately prevented any states from executing juveniles under the age of 18, thereby asserting the new standard for the death penalty age requirement that persists today. The impact of the ruling was immediately felt by many death penalty states, for 72 death sentences for young juveniles were eradicated because of the 2005 ruling (Justices abolish death penalty for juveniles). The decision also helped clarify the standards for all future cases. Whereas in the past prosecutors would consider and often seek the death penalty for juveniles who had committed atrociously violent crimes, the precedent of the Simmons ruling effectively prevents prosecutors from contemplating or seeking the death penalty for all future crimes committed by juveniles who are17 or younger when the crime occurred.

The Supreme Court ruling also curtailed the longstanding debate regarding whether or not juvenile death penalties were constitutional, for the ruling officially established that applying capital punishment on juveniles is a violation of the 8th amendment of the constitution because the juvenile death penalty reflects cruel and unusual punishment. Additionally, the ruling continued the trend of narrowing the scope of the death penalty. In 1988 the Court prohibited the execution of any juveniles 15 or younger, in 2002 the Court banned the use of capital punishment on mentally disabled individuals, and then in 2005 the Roper v. Simmons ruling excluded 16 and 17-year-old juveniles from qualifying for the death penalty (Roper v. Simmons, Laws.com). The trend of reducing the frequency at which our society executes criminals had been developing for several decades and the Simmons decision further perpetuated this downward trend of diminishing the use of capital punishment.

Although the death penalty can serve an important function by inflicting punishment on criminals who commit atrocious acts of violence and by deterring other citizens from committing horrendous crimes, the flaws that are associated with the death penalty has caused the issue of capital punishment to stimulate contentious debates throughout our nation’s history. Perhaps the most intense debates involving capital punishment relate to the morality or legality of executing juveniles who shock society by engaging in devastatingly violent behavior. The 2005 United States Supreme Court decision of Roper v. Simmons had a pivotal and consequential influence on the capital punishment issue and on the juvenile justice system, for the decision set a new precedent to which all states must comply, determined that it is unconstitutional to execute juveniles, and established the age of 18 or older as the requirement for when a criminal is eligible for the death penalty.

Works Cited

Dalton, Laura. "Stanford v. Kentucky and Wilkins v. Missouri: A Violation of an Emerging Rule of Customary International Law." William and Mary Law Review. N.p., 15 Jan. 1990. Web. 24 Feb. 2014. <http://scholarship.law.wm.edu/cgi/viewcontent.cgi?article=1921&context=wmlr>.

Denno, Deborah. "The Scientific Shortcomings of Roper v. Simmons ." The Ohio State University: Moritz College of Law. N.p., n.d. Web. 24 Feb. 2014. <http://moritzlaw.osu.edu/students/groups/osjcl/files/2012/05/Denno-PDF-04-06-06.pdf>.

Holsinger, Anne. "U.S. Supreme Court: Roper v. Simmons, No. 03-633." Death Penalty Information Center. N.p., n.d. Web. 23 Feb. 2014. <http://www.deathpenaltyinfo.org/u-s-supreme-court-roper-v-simmons-no-03-633>.

"Justices abolish death penalty for juveniles." NBC News. N.p., 1 Mar. 2005. Web. 24 Feb. 2014. <http://www.nbcnews.com/id/7051296/ns/us_news-crime_and_courts/t/justices-abolish-death-penalty-juveniles/#.Uw0uPvldV8R>.

"Roper v Simmons (2005)" UMKC School of Law. N.p., n.d. Web. 24 Feb. 2014. <http://law2.umkc.edu/faculty/projects/ftrials/conlaw/ropervsimmons.html>.

"Roper v. Simmons." Laws.com. N.p., n.d. Web. 24 Feb. 2014. <http://kids.laws.com/roper-v-simmons>.

"Roper v. Simmons." Chicago-Kent College of Law. N.p., n.d. Web. 24 Feb. 2014. <http://www.oyez.org/cases/2000-2009/2004/2004_03_633/>.

"Roper v. Simmons." Casebriefs. N.p., n.d. Web. 23 Feb. 2014. <http://www.casebriefs.com/blog/law/criminal-procedure/criminal-procedure-keyed-to-israel/sentencing-procedures/roper-v-simmons/>.

"Roper v. Simmons." Cornell University Law School. N.p., 13 Oct. 2004. Web. 24 Feb. 2014. <http://www.law.cornell.edu/supct/html/03-633.ZS.html>.

Schmalleger, Frank. Criminal justice today: an introductory text for the 21st century. 12th ed. Upper Saddle River, NJ: Pearson Prentice Hall, 2012. Print.