Juveniles V. Simmons Case Study

The narrative begins in 1993 with the sickening murder of Shirley Crook by seventeen-year-old Christopher Simmons. The Missourian had plotted to, “… commit burglary and murder by breaking and entering, tying up the victim, and throwing that victim off a bridge” (543 US 551, at 556-57). When the disfigured body of Mrs. Crook was located, authorities arrested Simmons who quickly confessed to the killing and was sent to court to be tried as an adult. During the trial, both the prosecutor and defense applied Simmons’ age as a justification for their arguments. The defense stated that Simmons’ age was a mitigating factor, citing several legal limitations on the capabilities of minors and in opposition, the prosecutor argued that it was actually

Simmons consequently appealed to the Missouri Supreme Court for post-conviction relief, but the court dismissed his motion in 1997, only for Simmons to file five years later in light of the recent Atkins v. Virginia (2002) ruling. Simmons argued that the Court’s reasoning concerning the “mentally retarded” applied to juveniles as well. The Missouri Supreme Court concurred, declaring that, “… a national consensus has developed against the execution of juvenile offenders,” and thus Simmons was resentenced to life imprisonment without eligibility for parole (112 S.W.3d 397). The Superintendent of the Potosi Correctional Center, Donald P. Roper, challenged this decision and was granted cert by the Supreme Court in

The investigation began with the Court looking for a national consensus against the juvenile death penalty by examining the actions of sentencing juries and state legislation. According to the Court’s calculations, thirty states opposed to the death penalty for juveniles equaled the number of states in Atkins opposed to the death penalty for mentally retarded offenders - a number deemed adequate to show a national consensus against the practice (Leavitt). Justice Kennedy moved on to engage in proportionality analysis and argued that capital punishment must be limited to individuals who commit, “...a narrow category of the most serious of crimes,” and are thus, “...the most deserving of execution” (543 US 551, at 568). Lastly, the analysis led Kennedy to note that America was one of the few countries that allowed capital punishment for offenders under eighteen and, “...acknowledged the overwhelming weight of international opinion against the juvenile death penalty” (543 US 551, at 571). The Court’s findings ended in a ruling in favor of Simmons and upholding the unconstitutionality of the juvenile death