Simmons V. Juveniles Summary

FACTS: Christopher Simmons was convicted and sentenced to death for capital crimes he committed when he was 17 years old. At the time of his conviction the Court’s ruling in Stanford v. Kentucky held that the 8th Amendment did not proscribe juvenile between the ages of 16 and 18 from being sentenced to death. In 2002 the Supreme Court ruling in the Atkins v. Virginia barred the use of the death penalty on mentally retarded offenders due to “evolving standards of decency” which put them in a class that is “categorically less culpable than the average criminal. In response to the above ruling, Simmons petitioned for postconviction relief on the basis that the reasoning in the Atkins decision applies to minors. His petition was heard by the
The majority advances their argument by listing some of the mental differences between adults and juveniles such as: “susceptibility to immature behavior”, lack of control over their environment and the peers that come with it, the ability to undergo a character change. These factors were enough for the Court to find the age group a suspect class and hold that they have diminished culpability, at least to an extent that the death penalty becomes an excessive
According to the dissent, the above claim has only been theorized in dicta, and is unsupported by actual precedent setting holdings. Justice Scalia claims that the Court is once again attempting to create precedent in order to legislate from the bench. Citing numerous cases including Gregg v. Georgia, 428 U.S. 153 (1976) “in a democratic society legislatures, not courts,…respond to…the moral values of the people” the dissent provides evidence for their stance, and highlight the majority’s lack