Atkins v. Virginia (2002)

Facts

  • Daryl Renard Atkins was convicted of abduction, armed robbery, and capital murder and sentenced to death for the murder of Eric Nesbitt.

  • At sentencing, a defense psychologist testified that Atkins had mild intellectual disability, based partly on an IQ score of 59. The State presented an expert who disputed that conclusion and considered Atkins to have at least average intelligence.

  • The jury again sentenced Atkins to death at resentencing, and the Virginia Supreme Court affirmed, relying on Penry v. Lynaugh.

  • Atkins argued that executing a person with intellectual disability violates the Eighth Amendment. The Supreme Court agreed to reconsider the issue in light of changes in state legislation since Penry.

Constitutional Issue

- Does executing individuals with intellectual disability constitute cruel and unusual punishment under the Eighth Amendment, as applied to the states through the Fourteenth Amendment?

Majority Opinion — Justice Stevens

  • The Eighth Amendment requires punishments to be proportionate to the offense and reflect the evolving standards of decency in society.

  • Legislative developments showed a national consensus against executing individuals with intellectual disability. The Court emphasized the consistent direction of state laws prohibiting these executions.

  • Individuals with intellectual disability have diminished culpability because of limitations in reasoning, judgment, communication, and impulse control. These limitations also create greater risks to the fairness and reliability of capital proceedings.

  • Execution does not adequately serve the purposes of retribution or deterrence for these individuals, and the risk of wrongful execution is heightened by their impairments.

Legal Test / Rule

  • The Eighth Amendment prohibits punishments that are excessive or inconsistent with the evolving standards of decency that mark the progress of a maturing society.

  • Courts examine objective evidence of contemporary values, particularly legislation enacted by state legislatures.

  • The Court also considers whether the punishment is proportionate to the offender's culpability and whether it serves legitimate penological purposes.

  • States must develop appropriate procedures for determining which individuals have intellectual disability and are therefore constitutionally ineligible for execution.

Dissenting Opinions

  • Chief Justice Rehnquist, joined by Justices Scalia and Thomas, argued that the majority improperly relied on foreign laws, professional and religious organizations, and public opinion polls. He believed courts should rely primarily on legislation and sentencing-jury practices when determining contemporary standards of decency.

  • Justice Scalia, joined by the Chief Justice and Justice Thomas, argued that the Constitution's text and history did not prohibit executing individuals with mild intellectual disability.

  • Scalia disputed the majority's claim of a national consensus, arguing that fewer than half of death-penalty states had enacted prohibitions and that the laws were relatively recent.

  • Both dissents opposed the Court's decision to establish a categorical constitutional prohibition rather than leave sentencing decisions to individual juries and state legislatures.

Concurring Opinions

- No concurring opinions are included in the provided excerpt.

Decision

  • The Court reversed the Virginia Supreme Court and remanded the case for further proceedings.

  • The Court held that executing individuals with intellectual disability violates the Eighth Amendment's prohibition against cruel and unusual punishment.

  • States must determine appropriate procedures for identifying individuals covered by this constitutional restriction.

Constitutional Provision(s)

  • Eighth Amendment: Prohibits cruel and unusual punishment.

  • Fourteenth Amendment: Applies the Eighth Amendment's prohibition to the states.