Atkins v. Virginia (2002)
- Sam Shepherd
- Jul 31, 2024
- 4 min read
Updated: Oct 27, 2024
By Stephanie Aguilar
Overview
Atkins v. Virginia is a landmark U.S. Supreme Court case in which the Court ruled that executing individuals with mental disabilities violated the Eighth Amendment which prohibits cruel and unusual punishment.
Summary
In 1996, Daryl Atkins kidnapped, robbed, and shot Eric Nesbitt eight times, killing him. Atkins and his accomplice, William Jones, were arrested and tried in court. In court, the prosecution relied on Jones’ testimony, Atkins’ prior criminal record, and testimonies from four earlier victims. The defense presented the testimony of Dr. Evan Nelson, a psychologist, concluded that Atkins was mildly mentally disabled because of earlier interviews, school and court records, and a standard intelligence test that showed Atkins had an IQ of 59. Despite this, Atkins “was convicted of abduction, armed robbery, and capital murder, and sentenced to death.” (Atkins v. Virginia).
However, the Virginia Supreme Court ordered a second sentencing hearing after finding that the trial court used a misleading verdict form. Expert witnesses were called for both sides, with Dr. Evan Nelson reaffirming that Atkins was mentally disabled, and Dr. Stanton Samenow arguing that Atkins had “average intelligence” and an antisocial personality disorder. The jury maintained the death sentence, which was affirmed by the Virginia Supreme Court. Atkins’ contention that his mental disability exempted him from the death penalty was rejected by the state court, citing Penry v. Lynaugh (1989).
Penry v. Lynaugh (1989) ruled “that executing capital murderers who are mentally disabled” does not violate the Eighth Amendment, but this decision was later overturned by Atkins v. Virginia.
The U.S. Supreme Court granted the certiorari to the Supreme Court of Virginia. In the Opinion, the Court concluded that the punishment must be proportional to the crime and not be “excessive.” The fairness of this punishment should be based on current “prevailing standards of decency,” and the court’s own judgement on whether the punishment aligns with the judgement of both the public and legislators.
The Court noted that in the 1990s and 2000s, many states, including Arkansas and Florida, enacted laws banning the death penalty for mentally disabled offenders. Society views individuals with mental disabilities as “less culpable than the average criminal” (Atkins v. Virginia). Furthermore, even in states where these executions are still allowed, such cases are extremely rare, with only five offenders known to have an IQ below 70 being executed since the Penry case.
Mentally disabled individuals can understand “the difference between right and wrong…but, by definition, they have diminished capacities to understand and process information, to communicate, to abstract from mistakes and learn from experience, to engage in logical reasoning, to control impulses, and to understand others’ reactions” (Atkins v. Virginia). Thus, diminishing their culpability.
The Court provided two reasons for excluding mentally disabled offenders from the death penalty. First, it questioned whether the death penalty’s goals of retribution and deterrence would apply to these individuals. Mentally disabled individuals have reduced culpability, which does not meet the criteria for retribution, and their “cognitive and behavioral impairments” would make it unlikely that the threat of execution would deter others from committing crimes. Secondly, the Court determined that their reduce capacity increases the risk of wrongful execution, as these individuals may struggle to defend themselves in legal proceedings.
The U.S. Supreme Court held that the death penalty for mentally disabled offenders is “excessive” and unconstitutional because it goes against the Eighth Amendment. The Virginia Supreme Court’s judgement was reversed and remanded for further review.
On remand, the jury found that Atkin’s IQ improved and was now considered mentally competent, resulting in another death sentence. However, due to allegations of misconduct from the prosecution side, the judge reviewing the case reduced Atkin’s sentence to life imprisonment.
Impact
The Atkins v. Virginia set a precedent by finding that the death penalty for individuals with mental disabilities is unconstitutional under the Eighth Amendment’s prohibition of cruel and unusual punishment. This ruling provides mentally disabled individuals with important legal protections because it ensures that those with cognitive impairments are not subjected to the death penalty, a punishment that does not accurately reflect their level of culpability.
This case has a huge influence on later decisions, such as Hall v. Florida (2014) and Moore v. Texas (2017). Following the Atkins ruling, Hall v. Florida challenged and expanded the standards for determining intellectual disability while Moore v. Texas redefined the evaluation criteria by rejecting the old standards and making it more in line with present-day medical guidelines. These two rulings had increased the protections for individuals with mental disabilities and improved the accuracy of future decisions.
States have also started to revise their laws and procedures for determining intellectual disability in capital cases. For example, California Penal Code Section 1376 established guidelines for evaluating intellectual disabilities and ensures that legal proceedings are conducted fairly.
Additionally, individuals with mental disabilities who had been sentenced to death were able to have their case reviewed and reevaluated following Atkins. As a result, many cases were changed from death sentences to life imprisonment without a chance of parole.
In conclusion, Atkins had a significant impact on individuals with disabilities in terms of capital punishment crimes. This decision resulted in new standards and criteria for determining intellectual disabilities, allowed specific individuals to appeal their sentences and receive life imprisonment instead. And it has also shaped legislation and legal rulings, providing more protection for individuals with mental disabilities.
Court Documents
To read the full Atkins v. Virginia Supreme Court Opinions and Dissents, click here:
Atkins v. Virginia, 536 U.S. 304 (2002)
To read the Penry v. Lynaugh Supreme Court Opinion and Dissents, click here:
Penry v. Lynaugh, 492 U.S. 302 (1989)
To read the Hall v. Florida Supreme Court Opinion and Dissents, click here:
Hall v. Florida, 572 U.S. 701 (2014)
To read the Moore v. Texas Supreme Court Opinion and Dissents, click here:
Moore v. Texas, 581 U.S. ___ (2017)
CA Penal Code § 1376 (2023)
Citations
Atkins v. Virginia, 536 U.S. 304 (2002)
By Stephanie Aguilar
