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Tuesday, April 24, 2012

Roper v. Simmons case brief, 543 U.S. 551 (2005)

Roper v. Simmons
543 U.S. 551 (2005)



Procedural History:
-U.S. Supreme Court review of a state court determination involving a death sentence for a juvenile offender.  After Christopher Simmons (D) was convicted of a murder he committed when he was 17 years old, the Missouri Supreme Court ruled that the death penalty was unconstitutional as applied to persons under the age of 18. The U.S. Supreme Court reviewed the decision.

Overview:

The state of Missouri (P) convicted Christopher Simmons (D) of a murder he committed when he was 17 years old. The Missouri Supreme Court ruled that the death penalty was unconstitutional as applied to persons under the age of 18, and set aside the sentence of death imposed on Simmons (D). The U.S. Supreme Court reviewed the decision, and in the process of reaching its conclusion, considered the opinion on the matter of the international community.

Issue:

Is the opinion of the world community relevant, though not controlling, to consideration of the juvenile death penalty in the United States?

Rule:

the opinion of the world community is relevant, though not controlling, to the consideration of the juvenile death penalty in the US.

Analysis:

Not stated in the casebook excerpt is that the Court applied the "evolving standards of decency" test Justice Kennedy cited a body of sociological and scientific research that found that juveniles have a lack of maturity and sense of responsibility compared to adults. The Court reasoned that in recognition of the comparative immaturity and irresponsibility of juveniles, almost every state prohibited those under age 18 from voting, sitting on juries, or marrying without parental consent Kennedy reasoned that the trend internationally against the death penalty for minors was relevant because of its basis in this evolving notion that the death penalty is inappropriate for juvenile offenders because of their instability and emotional imbalance.

Outcome:

(Kennedy, J.) Yes. The opinion of the world community is relevant, though not controlling, to consideration of the juvenile death penalty in the United States. Precedent suggests that reference to the laws of other countries and to international authorities for interpretation of the prohibition of "cruel and unusual punishments" is proper. Every country in the world has ratified the U.N. Convention on the Rights of the Child, which contains an express prohibition on capital punishment for crimes committed by juveniles under 18, except Somalia and the United States. Since 1990, only seven countries other than the United States have executed juvenile offenders, and since then each country, except the United States, has either abolished capital punishment for juveniles or made public disavowal of the practice. The United Kingdom's abolishment of the death penalty for juveniles, which is particularly relevant given the ties between the United Kingdom and the United States, occurred before the international conventions on the subject were created. International opinion against the death penalty for minors is based in large part on the understanding that the instability and emotional imbalance of young people may often be a factor in the crime, and that opinion, while not controlling, is relevant. The Eighth and Fourteenth Amendments forbid imposition of the death penalty on offenders under the age of 18 when the crime was committed. Affirmed.

Link to case:  543 U.S. 551 (2005)

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