ROPER V. SIMMONS

This is an audio case brief of Roper v. Simmons, 543 U.S. 551 (2005).  The audio brief provides a full case analysis. However a written summary of the case is provided below.

Table of Contents

FACTS

At the age of 17, while still a Junior in high school, Christopher Simmons decided he wanted to kill someone. He talked things over with two friends, Charles Benjamin and John Tessmer, about the possibility of committing burglary and murdering someone. He invited the two to join him. Because Benjamin and Tessmer were 15 and 16 respectfully, Simmons assured the two boys they would get away with it because they were all minors. Although both boys initially agreed to Simmons plan, Tessmer backed out on the night of the murder.

On September 8, 1993, around 2am in the morning, Simmons and Benjamin headed for Shirley Crook, the victim’s home. The two found a back window cracked open at the rear of Crook’s home. They opened the window, reached through, unlocked the back door, and entered Mrs. Crook’s home. Mrs. Crook was awaken when Simmons turned on the hallway light. She yelled “who is there?” In response, Simmons entered Mrs. Crooks bedroom where he recognized her from a previous car accident. According to Simon’s own admission to friends, seeing Mrs. Crook’s face confirmed his own resolve to murder her because “the bitch seen his face.”

When Simmons entered Mrs. Crooks bedroom, he ordered Mrs. Crook out of her bed. She refused to comply. Simmons then forced her to the floor with Benjamin’s help. While Benjamin guarded Mrs. Crook in the bedroom, Simmons found a roll of duct tape, returned to the bedroom, and bound her hands behind her back. Simmons and Benjamin used the duct tape to cover her eyes and mouth, and bind her hands. They walked Mrs. Crook from her home and placed her in the back of her minivan. Simmons drove the van from Mrs. Crook’s home in Jefferson County to Castlewood State Park in St. Louis County. After, the two perpetrators put Mrs. Crook in her minivan and drove to a state park. There, they reinforced the bindings, covered her head with a towel, and walked her to a railroad trestle spanning the Meramec River. They tied her hands and feet together with electrical wire, wrapped her whole face in duct tape and threw her from the bridge, drowning her in the waters below.

On the afternoon of September 9, Steven Crook  returned home from an overnight trip, he found his bedroom in disarray, and reported his wife missing. On the same afternoon fishermen recovered the victim’s body from the river.

The next day, after receiving information of Simmons’ involvement, police arrested him at his high school and took him to the police station in Fenton, Missouri. The State charged Simmons with burglary, kidnaping, stealing, and murder in the first degree. He was trailed as an adult. Simmons was found guilty of murder and sentenced to death at the age of 18 years old.

Following his sentence, a new court ruling in Atkins v. Virginia barred the execution of defendants who were mentally incapacitated. Simmons then filed a post-conviction relief arguing that under Atkins, the 8thamendment also barred the execution of minors. The Missouri supreme court agreed with him. The court overturned his death sentence and instead sentenced him to “life imprisonment without eligibility for probation, parole, or release except by act of the Governor.”

THE U. S. SUPREME COURT agreed to further review Simmons case.

ISSUE

The issue for the Supreme Court to look at is whether the 8th amendment forbids imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed.

RULE

The 8th amendment prohibits cruel and unusual punishments. Capital punishment must be limited to those offenders who commit “a narrow category of the most serious crimes” and whose extreme culpability makes them “the most deserving of execution.”

APPLICATION

The court begun its analysis by considering the capability of minors.

The court found that minors have less capability that adults who commit capital murder for three reasons:

  • Minors below the age of 18 lack maturity and have an underdeveloped sense of responsibility as compared to adults. And these qualities often result in impetuous and ill-considered actions and decisions.
  • The second area of difference between adults and minors is that juveniles are more vulnerable or susceptible to negative influences and outside pressures, including peer pressure than adults are.
  • The third broad difference is that the character of a juvenile is not as well formed as that of an adult. The personality traits of juveniles are more transitory, less fixed. A heinous crime committed by a juvenile is evidence of irretrievably depraved character.

Additionally, there are two distinct social purposes served by the death penalty:  retribution and deterrence of capital crimes by prospective offenders. Whether viewed as an attempt to express the community’s moral outrage or as an attempt to right the balance for the wrong to the victim, the case for retribution is not as strong with a minor as with an adult. Retribution is not proportional if the law’s most severe penalty is imposed on one whose culpability or blameworthiness is diminished, to a substantial degree, by reason of youth and immaturity.

As for deterrence, it is unclear whether the death penalty has a significant or even measurable deterrent effect on juveniles. The likelihood that the teenage offender has made the kind of cost-benefit analysis that attaches any weight to the possibility of execution is so remote as to be virtually nonexistent. To the extent the juvenile death penalty might have residual deterrent effect, it is worth noting that the punishment of life imprisonment without the possibility of parole is itself a severe sanction, in particular for a young person.

CONCLUSION

The court affirmed the lower court’s decision to sentence Simmons to life in prison without the parole.

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