Atkins v. Virginia

Background

Daryl Renard Atkins was convicted of abduction, armed robbery, and capital murder for the abduction, robbery, and fatal shooting of Eric Nesbitt. At sentencing a psychologist testified that Atkins had a full scale IQ of 59 and was "mildly mentally retarded." Virginia courts affirmed his conviction and death sentence after a resentencing, though some state justices dissented, and the Supreme Court granted review to reconsider whether executing a mentally retarded person violates the Eighth Amendment.

Reasoning

The Court asked whether executing people with mental retardation is "cruel and unusual" under the Eighth Amendment (which bans excessive or cruel punishments). It examined legislative trends, professional definitions, and research about impaired reasoning, impulse control, and adaptive skills. The majority concluded that mentally retarded offenders have diminished moral culpability and that their execution does not advance retribution or deterrence and increases the risk of unfair or unreliable capital proceedings. Relying on an apparent national consensus against such executions, the Court held they are unconstitutional and reversed the Virginia decision.

Real world impact

The ruling prevents states from executing people who meet clinical definitions of mental retardation and requires states to create procedures to identify such offenders. It reduces the risk of wrongful executions and changes how juries and prosecutors handle mitigation evidence. The Court left to the States the task of defining and enforcing the ban, so procedures and standards will vary.

Dissents or concurrances

Justices Rehnquist and Scalia dissented, arguing there is no reliable national consensus, criticizing the majority's reliance on polls and foreign opinion, and warning that courts should not override legislatures or juries. They also cautioned about feigned disability and the practical difficulties of creating a categorical rule.