Atkins v. Virginia
536 U.S. 304 (2002)

  • Atkins and Jones abducted, robbed, and killed a guy. They were caught and charged with first-degree murder.
  • Atkins was found guilty of first-degree murder and sentenced to death. He appealed.
    • Atkins argued that because he was mentally retarded, executing him would amount to cruel and unusual punishment in violation of the 8th Amendment.
  • The Appellate court upheld the sentence. Atkins appealed.
  • The Virginia Supreme Court upheld the sentence. Atkins appealed.
  • The US Supreme Court overturned the sentence.
    • The US Supreme Court found that the execution of mentally handicapped individuals violated the 8th Amendment’s prohibition of cruel and unusual punishments.
    • The Court noted that unlike other provisions of the Constitution, the Eighth Amendment should be interpreted in light of the “evolving standards of decency that mark the progress of a maturing society.”
      • The Court noted that a national consensus that the mentally retarded should not be executed had emerged.
    • The Court found that “relationship between mental retardation and the penological purposes served by the death penalty” justifies a conclusion that executing the mentally retarded is cruel and unusual punishment that the 8th Amendment should forbid.
      • Basically, unless it can be shown that executing the mentally retarded promotes the goals of retribution and deterrence, doing so is nothing more than “purposeless and needless imposition of pain and suffering,” making the death penalty cruel and unusual in those cases.
    • The Court noted that people with mental disabilities have difficulty communicating and can’t help with their defense as much. And they especially have problems communicating feelings of remorse to a jury, which could result in harsher sentences.
    • The Court left it up to the States to determine exactly how mentally handicapped a person had to be in order to disallow the death penalty.
  • Btw, a jury in Virginia then decided that Atkins was intelligent enough to be executed on the basis that the constant contact he had with his lawyers had intellectually stimulated him and raised his IQ above 70, making him competent to be put to death under Virginia law.