Atkins v. Virginia (2002)
Precedents
In McCoy v. Ohio, an individual with both mental retardation and paranoid schizophrenia refused to take medications regularly for the latter condition. Partially as a result of this refusal, his behavior became violent during times of non-medication.
Notable Dissenting opinions
Opinion 1
Opinion 2
Justice Hassell and Justice Koontz dissented. They rejected Dr. Samenow's opinion that Atkins possesses average intelligence as "incredulous as a matter of law," and concluded that "the imposition of the sentence of death upon a criminal defendant who has the mental age of a child between the ages of 9 and 12 is excessive.
Chief Justice Rehnquist, with whom Justice Scalia and Justice Thomas join, dissenting.
The question presented by this case is whether a national consensus deprives Virginia of the constitutional power to impose the death penalty on capital murder defendants like petitioner, i.e., those defendants who indisputably are competent to stand trial, aware of the punishment they are about to suffer and why, and whose mental retardation has been found an insufficiently compelling reason to lessen their individual responsibility for the crime.
Decision
Reasoning
The Verdict
6 votes for Atkins, 3 votes against.
In a 6-3 opinion delivered by Justice John Paul Stevens, the Court held that executions of mentally retarded criminals are "cruel and unusual punishments" prohibited by the Eighth Amendment. Since it last confronted the issue, the Court reasoned that a significant number of States have concluded that death is not a suitable punishment for a mentally retarded criminal.
How the case got to the Supreme Court and a summary of arguments
Arguments
How the case got to the Supreme Court
Petitioner Atkins was convicted of capital murder and related crimes by a Virginia jury and sentenced to death. The Virginia Supreme Court relied on Penry v. Lynaugh, 492 U. S. 302, in rejecting Atkins' contention that he could not be sentenced to death because he is mentally retarded.
Those mentally retarded persons who meet the law's requirements for criminal responsibility should be tried and punished when they commit crimes. Because of their disabilities in areas of reasoning, judgment, and control of their impulses, however, they do not act with the level of moral culpability that characterizes the most serious adult criminal conduct. Moreover, their impairments can jeopardize the reliability and fairness of capital proceedings against mentally retarded defendants.
Case Brief and Legal, and Political issues
Case Brief
Legal, Social or Political Issues
Atkins (D) however appealed against the ruling of the trial court on the ground that sentencing a mentally retarded criminal to death was a cruel and unusual punishment under the Eighth Amendment.
Issue:
Under the Eighth Amendment, is the capital punishment of a mentally retarded convict cruel and unusual?
Atkins Daryl (D) was sentenced to death for shooting a patron of an automated teller machine and for robbery, after he was found guilty of abduction, capital murder and armed robbery. A verdict of “mildly mentally retarded” pertaining to the health of Atkins (D), was given by a forensic psychologist. This verdict of the psychologist was based on the interview he had with Atkins (D) and with others who knew him, review of school and court records of other crimes and a standard intelligence test which showed that Atkins (D) had a full scale IQ of 59.