Law School Case Brief
Atkins v. Virginia - 536 U.S. 304, 122 S. Ct. 2242 (2002)
The death penalty is excessive punishment for a mentally retarded criminal and the U.S. Constitution places a substantive restriction on a state's power to take the life of a mentally retarded offender.
Defendant Atkins was convicted in a Virginia trial court on charges of abduction, armed robbery, and capital murder that arose out of a 1996 incident. At a second capital sentencing hearing, after an appellate court ruling that the first hearing had used a misleading verdict form, the defense presented testimony by a forensic psychologist who said that Atkins was mildly mentally retarded, with an IQ of 59, while a prosecution expert witness expressed the view that Atkins was of at least average intelligence. A jury again sentenced Atkins to death.
On appeal, the Supreme Court of Virginia, in affirming the imposition of the death penalty, relied on the authority of Penry v. Lynaugh in rejecting Atkinsi claim that because he allegedly was mentally retarded, he could not be sentenced to death. Penry v. Lynaugh did not categorically prohibit death sentences for criminal defendants who were mentally retarded.
Was the death penalty sentence on Atkins, who was said to be mentally retarded, proper?
In both penalty phases, the defense relied on the conclusion of a forensic psychologist that Atkins was mildly mentally retarded. The Supreme Court of the United States noted that the practice of executing mentally retarded criminals had become truly unusual, and concluded that a national consensus had developed against it. Construing and applying the Eighth Amendment in the light of evolving standards of decency, the Court concluded that such punishment was excessive and that the U.S. Constitution placed a substantive restriction on a state's power to take the life of a mentally retarded offender. The Court reasoned that the deficiencies of mentally retarded criminals did not warrant an exemption from criminal sanctions, but they did diminish their personal culpability. Mentally retarded defendants in the aggregate faced a special risk of wrongful execution. The Court noted that there was more disagreement about how to determine which offenders were in fact retarded than over whether or not the death penalty was appropriate for them. The Court stated that it would leave to the states the task of developing appropriate ways to enforce the constitutional restriction upon its execution of sentences. The judgment was reversed and the case was remanded for further proceedings.
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