Penry v. Lynaugh Case of 1989

Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

Penry v. Lynaugh is a Supreme Court case from 1989, where the Court was asked to determine whether the imposition of the death penalty on a mentally handicapped defendant was 'cruel and unusual' punishment. This lesson discusses the facts of the Penry case, as well as the Supreme Court's analysis and decision.

Cruel and Unusual Punishment

What is 'cruel and unusual' punishment?

The Eighth Amendment to the United States Constitution prohibits the government from imposing 'cruel and unusual' forms of punishment on convicted criminals. Generally, punishments have received the 'cruel and unusual' label for being excessively severe, disproportionately related to the offense, or an affront to human dignity. Over the years, the Supreme Court has banned a number of punishments under the Eighth Amendment, including drawing and quartering, public dissection, and disembowelment.

In 1989, the Supreme Court was asked to consider whether the execution of mentally handicapped defendants constituted 'cruel and unusual' punishment under the Eighth Amendment.

The Facts of Penry v. Lynaugh

In 1979, John Paul Penry forced his way into 22-year-old Pamela Moseley's Texas apartment. Penry held a pocket-knife to Moseley's neck and forced her into her bedroom, where he raped and stabbed her to death.

A Texas court convicted Penry of rape and murder, and sentenced him to death. Penry appealed his death sentence all the way to the Supreme Court, where he argued that his execution would violate his Eighth Amendment rights against 'cruel and unusual' punishment. Penry was severely mentally challenged, having the mental faculties of a seven-year-old child.

The Question Presented to the Supreme Court

Does the execution of a mentally handicapped individual violate the Eighth Amendment's prohibition on 'cruel and unusual' punishment?

The Holding and Analysis of the Supreme Court

The Supreme Court of the United States held that the execution of mentally handicapped individuals doesn't violate the Eighth Amendment. In other words, the Court determined that imposing the death penalty on mentally-challenged defendants was not 'cruel and unusual' punishment.

In reaching its decision, the Supreme Court noted that imposing the death penalty on defendants who are 'wholly lacking the capacity to appreciate the wrongfulness of their actions' may indeed amount to the infliction of 'cruel and unusual' punishment. According to the Supreme Court, Penry, having been found competent to stand trial, was not 'wholly lacking in the capacity' to understand that what he did was wrong. Therefore, he was eligible for receiving the death penalty for his crimes.

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