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State Ex Rel. Simmons v. Roper
Citations: 112 S.W.3d 397; 2003 Mo. LEXIS 123; 2003 WL 22006834Docket: SC 84454
Court: Supreme Court of Missouri; August 26, 2003; Missouri; State Supreme Court
Christopher Simmons, sentenced to death for a murder committed at age 17, argues that executing him constitutes cruel and unusual punishment under the Eighth Amendment. The Supreme Court previously ruled in Thompson v. Oklahoma that executing individuals aged 15 or younger is cruel and unusual. In Stanford v. Kentucky, however, it allowed executions for those aged 16 and 17, stating a lack of national consensus against such practices. Simmons did not contest his age during his trial due to Stanford’s precedent, though he cited it as a mitigating factor. His conviction and death sentence were upheld by the Missouri Supreme Court. Following the Supreme Court's decision in Atkins v. Virginia, which recognized a national consensus against executing the mentally retarded, Simmons now contends that a similar consensus against executing juveniles has emerged since Stanford. The Missouri Supreme Court agrees, citing evidence of legislative changes over the past fourteen years: 18 states now prohibit juvenile executions, 12 states ban the death penalty altogether, and no state has lowered the execution age below 18. Consequently, the court determines that executing juveniles violates the Eighth and Fourteenth Amendments and re-sentences Simmons to life imprisonment without the possibility of parole, probation, or release, except by gubernatorial action. The court also addresses the state's argument against considering this issue, stating that it can still evaluate the substantive question of juvenile death penalty prohibitions, referencing principles from Penry and Teague v. Lane regarding retroactive application. Penry affirmed that the first exception in Teague encompasses rules that not only forbid certain criminal punishments based on conduct but also those prohibiting specific punishments for particular classes of defendants due to their status or offense. The Supreme Court indicated that if the Eighth Amendment were interpreted to categorically prohibit the execution of mentally retarded individuals, such a rule would be retroactively applicable to defendants seeking collateral review. While Penry found no national consensus against executing mentally retarded individuals in 1989, Atkins identified a consensus by 2002, establishing a substantive Eighth Amendment restriction against such executions. The court in Johnson v. State recognized that Atkins applied retroactively, and Van Tran v. State held similarly prior to Atkins. Additionally, the document discusses the implications of Eighth Amendment protections regarding the execution of juveniles. If it is determined that the Eighth Amendment prohibits executing individuals under 18 at the time of their offense, this rule would also fall under the first Teague exception, making it applicable to cases under collateral review, as in Mr. Simmons' situation. The excerpt references Reed v. Ross, which allows for constitutional claims that are novel and not previously available to counsel, providing grounds for not raising such claims in state procedures. The analysis of the death penalty for juveniles references the Supreme Court's decision in Thompson v. Oklahoma, which concluded that the Eighth Amendment categorically prohibits executing individuals aged 15 or younger at the time of their crimes. Justice Stevens emphasized that judges should consider evolving standards of decency in determining cruel and unusual punishment, assessing legislative actions, jury perspectives, and views from national and international organizations. The Supreme Court evaluated the appropriateness of executing juveniles, particularly focusing on individuals under 16 years old. It concluded that contemporary standards of decency indicate such young individuals lack the culpability justifying the death penalty. Legislative analysis revealed considerable variation among states regarding capital punishment for minors: fourteen states prohibit it, nineteen states lack a minimum age requirement, and eighteen states set the minimum age between 16 to 18. The Court noted the rarity of death penalty imposition on those under 16, with only a handful executed in the 20th century, and deemed recent sentences for young offenders as "cruel and unusual." Furthermore, the Court considered the positions of national organizations like the American Bar Association, which opposed juvenile executions, as well as international practices, highlighting that many countries have abolished the death penalty for juveniles. The Court acknowledged broad consensus on juveniles being less mature and responsible than adults, leading to a conclusion that they should bear lesser culpability for their crimes. It found the justifications of retribution and deterrence inadequate for those under 16, ultimately determining that executing individuals in this age group constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments. In Stanford v. Kentucky, Justice Scalia ruled that the Eighth and Fourteenth Amendments do not prevent the death penalty for crimes committed by individuals aged 16 or 17. He emphasized that current standards of cruel and unusual punishment should be determined by state statutes, noting that while most states do not execute juvenile offenders, a majority of states that permit capital punishment do allow it for those aged 16 or 17. Despite acknowledging that juries impose death sentences on juveniles less frequently than on adults, Stanford concluded that this did not warrant a total prohibition on such sentences. The Court dismissed the relevance of state laws restricting activities for those under 18 and deemed the influence of national organizations and international practices as inadequate for establishing a national consensus against executing juveniles. In a concurrent decision, Penry v. Lynaugh found no national consensus against executing mentally retarded individuals, with the Court affirming that the definition of cruel and unusual punishment evolves with societal standards. At the time of the ruling, only three jurisdictions had laws prohibiting the death penalty for the mentally retarded, which, combined with other states that entirely reject capital punishment, did not constitute sufficient evidence of a national consensus. Additionally, Penry failed to show that juries significantly avoided sentencing mentally retarded defendants to death. The Supreme Court determined that it could not definitively state that all mentally retarded individuals lack the culpability necessary for the death penalty, indicating there was insufficient evidence of a national consensus against executing such individuals under the Eighth Amendment. In the 2002 case of Atkins v. Virginia, the Court revisited this issue, reversing Daryl Atkins' death sentence and ordering an evaluation of his mental status. The Court emphasized that societal standards of decency are fluid, affecting what constitutes cruel and unusual punishment. Atkins' analysis mirrored that of earlier cases, focusing on: (a) objective evidence from state legislation prohibiting the death penalty for the mentally retarded, (b) the frequency of such sentences being imposed, (c) perspectives from national organizations and other countries, and (d) an independent assessment of evolving standards regarding the death penalty's application to mentally retarded individuals. Notably, in the thirteen years since the Penry decision, fourteen states (including Missouri) had enacted laws barring the death penalty for the mentally retarded. While New York and Nebraska reinstated the death penalty, they exempted the mentally retarded from its application. Overall, 18 states and the federal government prohibited such executions. The Court highlighted that the consistency in states' legislative actions was more significant than their number, noting that no state had passed new laws permitting executions of the mentally retarded since Penry. This trend, especially in a climate favoring tough crime legislation, indicated a societal view of mentally retarded offenders as categorically less culpable than typical criminals. The Court observed that certain states, like New Hampshire and New Jersey, had not executed any mentally retarded individuals for decades, diminishing the likelihood of enacting laws against such executions. In states where executions were still performed, the execution of mentally retarded offenders was rare, with only five executed in the thirteen years post-Penry. This led the Court to determine that a national consensus against executing mentally retarded individuals had emerged. The consensus against this practice was further supported by the legislative changes over the last thirteen years, the limited application of the death penalty where allowed, and opposition from professional organizations, such as the American Psychological Association and the American Association of Mental Retardation. Additionally, the sentiments of religious groups and global communities were overwhelmingly against such executions. Polling data reflected a broad agreement among Americans, including death penalty supporters, that executing mentally retarded individuals was wrong. While the Court noted that the opposition from these groups was not definitive, it reinforced its conclusion of a consensus aligned with legislative evidence. The Supreme Court conducted an independent assessment of whether executing mentally retarded offenders should be prohibited. It found that the justifications of retribution and deterrence did not support such executions, arguing that if the culpability of an average murderer did not justify the death penalty, the lesser culpability of mentally retarded offenders certainly did not. The Court noted that the cognitive and behavioral impairments associated with mental retardation hindered these individuals' understanding of execution as a penalty and their ability to control their conduct accordingly. It rejected the notion that mental retardation could merely be a mitigating factor, emphasizing that mentally retarded individuals are more prone to false confessions and less capable of assisting their defense, which could result in an appearance of lack of remorse. Ultimately, the Court concluded that the death penalty was an unsuitable punishment for mentally retarded criminals. The principles established in Atkins, Thompson, Penry, and Stanford are proposed to be applicable in assessing the execution of juveniles, indicating that Stanford does not prevent the consideration of a current national consensus against the death penalty for juveniles. The state contends that the Supreme Court's decision in Atkins is irrelevant to the current case because it is bound by the precedent set in Stanford, which allowed the execution of individuals aged 16 or 17 at the time of their crimes. This perspective overlooks the fundamental basis of Stanford and related cases, which asserts that the Eighth Amendment's prohibition is interpreted in a flexible manner according to contemporary societal standards. Atkins reaffirmed that such standards should reflect current societal views rather than those from earlier decades. The court is tasked with evaluating whether a modern national consensus opposes the death penalty for juveniles, a determination that should not be restricted to the legal context of 1989 when Stanford was decided. The authority to assess the current standards of decency—specifically as of 2003—remains with the court. Atkins provides grounds for reconsidering Stanford by highlighting that societal views have evolved, with more states now prohibiting the execution of juveniles and advancements in understanding juvenile brain development. The court will evaluate the national consensus against the juvenile death penalty through various factors, including legislative actions, the frequency of juvenile executions, societal opinions, and whether such penalties align with evolving standards of decency as mandated by the Eighth and Fourteenth Amendments. Historically, legislative actions have increasingly moved against the juvenile death penalty since the Penry decision, which recognized that only a minimal number of states had outlawed the execution of mentally retarded individuals at that time, insufficient to indicate a national consensus. The document highlights a significant trend in the legal landscape regarding the death penalty for juvenile offenders. Initially, eleven states had prohibited the juvenile death penalty at the time of the Stanford decision, which was insufficient to establish a national consensus. Since then, five additional states have enacted bans, either by raising the execution age to 18 or reinstating the death penalty only for those 18 and older at the time of their offense. The Washington Supreme Court also ruled against imposing the death penalty on juveniles, bringing the total to sixteen states, plus federal civilian and military courts, that require a minimum age of 18 for execution. When including the twelve states and the District of Columbia that completely ban the death penalty, a total of twenty-eight jurisdictions prohibit juvenile executions, closely mirroring the thirty states that prohibited execution of the mentally retarded at the time of the Atkins decision. The trend shows no states have reduced the age of execution since Stanford; in fact, many are considering raising it. The document notes the infrequency of executing juvenile offenders, with only six states having executed such offenders since Stanford, and most executions occurring in Texas, Virginia, and Oklahoma. Historical data indicates that while 366 juvenile offenders were executed since 1642, only twenty-two have been executed in the recent era from 1973 to 2003, with a substantial majority occurring in a few states. This reflects a broader societal shift against the juvenile death penalty, mirroring the earlier opposition to executing the mentally retarded. Alabama, Arizona, Arkansas, Delaware, Idaho, Kentucky, Mississippi, Nevada, Pennsylvania, South Dakota, Utah, and Wyoming permit the death penalty for 16-year-olds, while Florida, New Hampshire, and North Carolina allow it for 17-year-olds; however, no executions of juveniles have occurred in these states since the death penalty's reinstatement in 1976. Except for South Dakota and New Hampshire, these states have executed other offenders during this period. Although some death sentences have been imposed on juveniles, they have typically been overturned, with South Carolina being among a limited number of states executing juveniles since 1976. The number of executions of mentally retarded individuals exceeds those of juveniles, indicating that the death penalty's application to juveniles is rare, with Missouri being the only state currently considering multiple juvenile executions. There is significant opposition to the juvenile death penalty from a wide array of professional, social, and religious organizations, many of which submitted amicus briefs against it. Recent polls indicate that only 34% of Missourians support the death penalty for juveniles. While past decisions downplayed the importance of such opposition, recent rulings, particularly in Atkins, suggest a renewed acknowledgment of evolving standards of decency influencing the legality of the death penalty for juveniles. Opposition to the juvenile death penalty is supported by a diverse range of U.S. groups, aligning with legislative evidence indicating that current standards of decency do not allow for such punishment. The international community has also increasingly opposed juvenile executions, with Article 37(a) of the United Nations Convention on the Rights of the Child and various treaties explicitly prohibiting them. Recent data from Amnesty International highlights that only Iran and the Democratic Republic of the Congo have conducted official executions of juveniles, while the U.S. accounts for five of the last seven juvenile executions. In Atkins v. Virginia, the Supreme Court evaluated whether the death penalty was appropriate for mentally retarded offenders, concluding that neither retribution nor deterrence justified such a punishment due to their reduced culpability and capacity to understand the consequences of their actions. The Court determined that mentally retarded individuals should be categorically exempt from execution to mitigate the risks of false confessions and wrongful executions. Analogously, the same rationale applies to juveniles: the concepts of retribution and deterrence are ineffective, and the potential for wrongful execution is heightened due to their developmental stage. The Court noted that adolescents are generally less mature and responsible than adults, as established in Thompson v. Oklahoma, reinforcing the argument against the juvenile death penalty. Less culpability should be attributed to juvenile crimes compared to those committed by adults, as established in *Thompson v. Oklahoma* and echoed in *Eddings v. Oklahoma*. Juveniles, particularly during their formative years, are generally less mature and responsible, making them more susceptible to influence and psychological harm. Their inexperience, limited education, and heightened emotional responses contribute to their inability to fully evaluate the consequences of their actions. Consequently, the motivations behind juvenile conduct are often driven by emotion or peer pressure rather than rational decision-making. The death penalty's deterrent effect is significantly diminished for juveniles due to their developmental stage and the rarity of executions for individuals aged 16 and 17, which reduces the likelihood that they consider the death penalty in their decision-making process. Additionally, younger offenders face a greater risk of wrongful execution, as they have less community ties, fewer opportunities for mitigating behavior, and are more prone to waive rights and provide false confessions. While Missouri law allows for youth to be considered as a mitigating factor, the case illustrates that this can be turned against the defendant. In Mr. Simmons' trial, the prosecution argued that his age should not protect him, framing his age as something frightening rather than mitigating. This highlights the complex and often contradictory application of youth as a factor in legal proceedings. Mr. Simmons' youth was argued to indicate increased immorality and potential danger, providing grounds for the death penalty. The Court determined that executing individuals for crimes committed under the age of 18 violates the Eighth Amendment's prohibition against cruel and unusual punishment, as interpreted in light of evolving societal standards. Consequently, the Court vacated Mr. Simmons' death sentence and imposed a life sentence without the possibility of parole, probation, or release except by gubernatorial pardon. Judge Wolff concurred, emphasizing that the Eighth Amendment forbids the execution of individuals who were not capable of adult moral judgment at the time of their crime. He referenced previous Supreme Court cases that draw a clear age line for death penalty eligibility, noting that the legislature currently sets this line at age 15. However, the prevailing opinion now establishes the age at 18, reflecting a judicial consensus that those below this age cannot be fully responsible for their actions, despite facing adult legal consequences in some cases. Wolff acknowledged the importance of legislative judgment in determining age thresholds for capital punishment, advocating for deference to legislative decisions rather than subjective judicial determinations. The Thompson decision affirms that line drawing in capital cases is a judicial responsibility aimed at protecting Eighth Amendment rights. Historically, common law has recognized age categories for criminal responsibility, establishing that individuals under seven lack criminal capacity, while those 14 and older are fully responsible. Between ages seven and 14, there exists a rebuttable presumption of incapacity, placing the burden on the prosecution to prove otherwise. Notable historical examples illustrate grim applications of these principles, including the execution of young offenders. The evolving standards of decency, referenced by the U.S. Supreme Court, raise questions about how far these standards have progressed. Missouri's death penalty statute allows juries to consider age as a mitigating factor but lacks detail on its application. In the current case, both defense and prosecution utilized the defendant Simmons’ age in their arguments, with the defense highlighting the immaturity of 17-year-olds, while the prosecution suggested that Simmons' age indicated a potential for worsening behavior, arguing against mitigation. The principal opinion relies on the Eighth Amendment’s prohibition against cruel and unusual punishment, but if the Supreme Court disagrees with this evolution of decency, the issue may warrant case-by-case factual determinations. The opinion suggests adopting a common law presumption that individuals aged 16 or 17 are not fully responsible and thus ineligible for the death penalty, allowing the state to present evidence of full capacity while the defense can argue for a lack of responsibility, with the burden on the state to overcome this presumption. Responsibility for eligibility for the death penalty in juvenile cases should be determined by a jury, rather than by a strict age limit set by the Court. The use of age as a definitive criterion for 16 and 17-year-olds is problematic, as it does not accurately reflect maturity, judgment, and responsibility. This reliance on age can lead to "comparative injustice," where some capable individuals may be spared the death penalty while others who lack maturity may be executed. An alternative approach would involve establishing a presumption that individuals under 18 lack sufficient maturity for death penalty eligibility, which could be rebutted by the state with proof beyond a reasonable doubt. Individualized assessments in juvenile death penalty cases would help mitigate injustices related to age-based determinations. This presumption would not be based on the Eighth Amendment's prohibition against cruel and unusual punishments but rather on state law interpretations concerning capital sentencing. The judge expresses dissent, arguing that Missouri law allows for the death penalty for those over 16, reflecting the will of the people, and contends that the majority opinion contradicts the Supreme Court's ruling in Stanford v. Kentucky. The legal document discusses the case of Christopher Simmons, who was arrested for the murder of Shirley Crook when he was approximately 17 years old. Simmons seeks habeas corpus relief, arguing that his death sentence is unlawful due to his status as a juvenile at the time of the crime. He acknowledges the precedent set by Stanford v. Kentucky, which upheld the constitutionality of executing individuals aged 16 or 17, stating there is no societal consensus against such punishments and that they do not violate the Eighth Amendment's prohibition against cruel and unusual punishment. Simmons contends that the Supreme Court's decision in Atkins v. Virginia, which addressed the execution of intellectually disabled individuals, implicitly overrules the Stanford precedent. However, the document emphasizes that the Supreme Court has not overturned Stanford, and it is not within the authority of this court to do so. The summary reiterates that Stanford determined no societal consensus exists against capital punishment for those aged 16 and 17, as evidenced by state and federal statutes, jury behavior, and prosecutorial decisions. The Supreme Court declined to consider factors such as public opinion polls and views of interest groups when determining whether there exists a national consensus sufficient to justify a permanent prohibition on certain governmental actions. In Atkins v. Virginia, the Court did not overrule Stanford and specifically addressed the constitutionality of capital punishment for mentally retarded individuals, ruling it as cruel and unusual. The rationale included the lower moral culpability of mentally retarded persons and a prevailing consensus against such punishment evidenced by legislative and public standards. United States Supreme Court decisions are established as the supreme law of the land, binding state courts, regardless of disagreement with those decisions. For instance, in State Oil Co. v. Khan, the appellate court recognized a prior Supreme Court decision as flawed but felt obligated to adhere to it, a sentiment echoed by the Supreme Court in its affirmation of the appellate court's respect for the doctrine of stare decisis. The text also discusses a gradual shift in judicial attitudes towards arbitration, as noted in Rodriguez de Quijas v. Shearson/American Express, emphasizing that courts cannot unilaterally disregard prior Supreme Court rulings. A court should adhere to a Supreme Court precedent with direct applicability, even if it conflicts with other decisions, leaving the Supreme Court the authority to overrule its own rulings. The Supreme Court has refrained from overturning Stanford v. Kentucky, despite recent cases—Mullin v. Hain, In re Stanford, and Patterson v. Texas—each involving a defendant who was seventeen at the time of the crime. Although dissenting opinions have questioned Stanford's validity, the majority opinion of the court cannot disregard existing Supreme Court precedent. The appropriate channel for challenging this precedent is directly through the Supreme Court. Furthermore, the terms "juvenile death penalty" and "juvenile executions" specifically refer to individuals under 18 at the time of their crimes, even though some jurisdictions, including Missouri, classify 17-year-olds as adults for juvenile court purposes. Legislative changes regarding the juvenile death penalty since Stanford are limited, as noted in Atkins. The court concludes that the issue of retroactivity does not require further analysis under Stovall v. Denno due to the requirements set forth in Teague. Ultimately, the court recommends denying the writ. Eleven states and the federal government had already prohibited the death penalty for juveniles at the time of the Stanford decision, with two additional states enacting similar bans since then. Others are considering such measures, while two states have statutes explicitly barring executions for individuals under 18. Washington has also disallowed juvenile executions through a court decision. Furthermore, twelve additional states and the District of Columbia completely prohibit executions. In Godfrey v. Georgia, the Supreme Court invalidated a death sentence, determining that the petitioner's crimes did not demonstrate a substantially more depraved consciousness than that of a typical murderer. The dissent's view suggesting the Supreme Court would not extend Atkins principles to juvenile executions misinterprets the Court's stance; denials of writs do not imply opinions on case merits, as reiterated in Maryland v. Baltimore Radio Show and Teague v. Lane. Various states have enacted laws against juvenile executions, including Indiana and Montana. Although fewer states raised their minimum execution age after Stanford compared to those that barred the death penalty for the mentally retarded after Penry, this is partially due to prior actions taken against juvenile capital punishment. The irony lies in the broader recognition of the inappropriateness of the death penalty for juveniles occurring earlier than for the mentally retarded, which should not justify continuing juvenile executions. A list of organizations filed amicus curiae briefs in support of the petitioners in the Stanford case, including the American Bar Association, Child Welfare League of America, National Parents and Teachers Association, and various religious and social advocacy groups. These organizations collectively expressed their views on a dedicated website. The Stanford ruling did not dismiss the relevance of certain rationales for 16- or 17-year-olds facing capital punishment but deemed them irrelevant in this context. The Eighth and Fourteenth Amendments provided grounds for relief for Mr. Simmons, making it unnecessary to consider his alternative argument regarding the Missouri Constitution. Missouri law stipulates that the death penalty cannot be applied to those under 16 at the time of the crime. The excerpt references a Florida Supreme Court decision, which noted the judicial branch's role in determining age-related legal thresholds, acknowledging the potential arbitrariness in such decisions. Additional state laws regarding age restrictions for drinking, voting, medical consent, contract capacity, marriage, driving, will-making, and jury service are also cited. Courts assess the capacity of juveniles when determining whether to certify them for adult trials, considering factors such as age, maturity, and sophistication. In *State v. Thomas*, a 16-year-old defendant was reported to have low average intelligence but an understanding of right and wrong and the ability to make independent decisions. Evaluations similar to those used in certification proceedings may also be applied to assess whether a juvenile's capacity justifies the death penalty. In *Thompson v. Oklahoma*, dissenting opinions suggested that individualized consideration of maturity and moral responsibility is essential when contemplating the death penalty for juveniles. Justice Scalia acknowledged a national consensus against automatic death sentences for offenders under 16, emphasizing the need for individualized assessments. The legal framework implies that those aged 16 and above may be presumed eligible for the death penalty, placing the burden on the offender to establish their youth as a mitigating factor. However, the judiciary traditionally determines presumptions in death penalty cases, ensuring that the penalty is not misapplied. There is also a consideration that the presumption against the death penalty could extend to individuals under 21, aligning with the age of maturity for jurors. The justification for such a presumption is based on the notion that the death penalty is generally inappropriate for younger individuals, thus requiring the state to prove that an offender is mature enough to warrant such a sentence. Additionally, the court must ensure proportionality in sentencing under Missouri law, noting that the death penalty has seldom been applied to those under 18. Comparatively, the potential for a minor to receive the death penalty is extremely low, suggesting that such a sentence would be disproportionate. The interpretation of constitutional law is binding on the states, reinforcing the necessity for careful consideration in these cases.