Summary of Atkins v. Virginia
Facts: Atkins was convicted of abduction, armed robbery and capital murder. During the penalty phase of his trial, defense counsel relied on a forensic psychologist as the sole witness to testify that Atkins was mentally retarded, albeit mildly rather than profoundly. Atkins was sentenced to capital punishment, but the Virginia Supreme Court ordered a second sentencing hearing since the trial court erred by using a misleading verdict form. During the second sentencing hearing, the same forensic psychologist was interviewed and testified, but the State decided to rebut the expert’s testimony regarding Atkins’ intelligence. Atkins was once again sentenced to death. In affirming the ruling, the Virginia Supreme Court relied on the reasoning presented in Penry v. Lynaugh, in rejecting Atkins’ contention that he could not be sentenced to death because per the forensic psychologist, he is mentally retarded. Atkins appealed the decision to the Supreme Court.
Issue: The legal question presented was whether imposing a sentence of capital punishment on mentally retarded persons constitutes cruel and unusual punishment in violation of the Eighth Amendment.
Holding: The Supreme Court held that imposing the death penalty on Atkins would constitute “cruel and unusual punishment" because he was diagnosed as being mentally retarded.
Majority Opinion: The majority of the Court held that yes, executing mentally retarded criminals constituted “cruel and unusual punishments” and was thus prohibited by the Eighth Amendment. The Court interestingly reasoned that the typical reasons for imposing the sentence, deterrence and punishment, didn’t really even work for the mentally retarded because they lacked the intellectual capacity to understand such punishment. It could therefore not be seen as a deterrence. The Court, specifically Justice Stevens, reasoned that, “Construing and applying the Eighth Amendment in the light of our ‘evolving standards of decency,’ we therefore conclude that such punishment is excessive and that the Constitution ‘places a substantive restriction on the State’s power to take the life’ of a mentally retarded offender.”
Dissenting Opinion: Chief Justice Rehnquist and Associate Justice Antonin Scalia dissented and Associate Justice Clarence Thomas joined both. The justices argued that similar to the Roper case, there had not been any clear cut moving away from executing mentally retarded individuals, but that states on a case by case basis had made their own judgments. Consequently, there was no need or reason to bar states from making this decision on their own based upon the believed or proven degree of mental retardation of convicts.
Conclusion: This case is essentially significant in the same manner as the Roper case, by which the Supreme Court ruled that executing mentally retarded individuals was contradictory to the nation’s evolving standards of decency.