Atkins v. Virginia: Case Brief

Instructor: Erin Krcatovich

Erin teaches undergraduate and graduate classes in Political Science, Public Policy, and Public Administration and has a PhD in Political Science.

Atkins v. Virginia is a 2002 Supreme Court case where the court ruled whether intellectually disabled persons convicted of crimes are eligible for the death penalty. In this lesson, we will learn about the death penalty, background of the case, and the Court's decision.

Atkins v. Virginia Case

One area of controversy related to the death penalty is whether individuals who are deemed to be ''mentally retarded'', or disabled based on diminished ''reasoning, judgment, and control of their impulses'' (536 U.S. 307), could be put to death if found guilty of a capital offense. In particular, the Atkins v. Virginia case asks the Court if this is cruel and unusual punishment as defined by the Eighth Amendment to the U.S. Constitution, punishment that is excessive and inappropriate, given the circumstances.

Daryl Atkins was convicted of abducting, robbing, and killing Eric Nesbitt in 1996 and sentenced to death. At trial, his attorneys offered testimony from a forensic psychologist who interviewed him and determined he was ''mildly mentally retarded'' (536 U.S. 308). The prosecution's expert witness disagreed with his diagnosis, claiming Atkins did not have diminished intelligence and so could understand the nature of his crime and the consequences. The Supreme Court of Virginia agreed that Atkins' intelligence was not enough of a reason to change his death sentence to life imprisonment. The Supreme Court agreed to take the case; the legal question at stake was, is it unconstitutional to sentence intellectually disabled convicts to death?

A Brief Look at the Death Penalty in America

In 2015, Nebraska made history when its legislature chose to ban capital punishment, better known as the death penalty. Each state's legislature has the right to decide whether or not crimes in their state are punishable by death and to set the limitations on when and how that punishment can be applied. There are some federal crimes for which the death penalty can be imposed, such as espionage, treason, and murder under certain circumstances (i.e., during a robbery, with a weapon of mass destruction, and so on).

Over the years, various Supreme Court rulings on the death penalty have changed the legal landscape under which it may be used. In 1972, the Supreme Court determined that all existing death penalty laws were cruel and unusual punishment (Furman v. Georgia, 408 U.S. 238), putting a freeze on convictions and commuting all existing sentences to life imprisonment. Four years later, the Court decided that the death penalty alone was not unconstitutional and so allowed states to begin issuing death penalty convictions once again (Gregg v. Georgia, 428 U.S. 153). The Court has also ruled that it is not appropriate to sentence a child to death, and that other crimes are not capital offenses, such as in Coker v. Georgia (433 U.S. 584, 1977), where the Court held that rape of an adult woman was not a capital offense.

One of the key factors in the Court's approval of death penalty statues is proportionality. The punishment must be appropriate for the crime. Among the criteria used to decide proportionality are how states treat other crimes, and how other states treat similar crimes.

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