Atkins v. Virginia

536 U.S. 304 (2002).

One-Sentence Takeaway:  Imposition of death penalty on a mentally retarded defendant violates the cruel & unusual punishment clause of the Eight Amendment.

Summary: Atkins and an accomplice abducted the victim, robbed him, forced him to take money out of his ATM, and then shot the victim eight times which caused the victim’s death.  Atkins was convicted of abduction, armed robbery, and capital murder.

During the penalty phase, defense presented expert testimony that Atkins had an IQ of 59 and was mildly mentally retarded.  Notwithstanding that testimony, Atkins was sentenced to death by the jury.

The Supreme Court of the United States reversed and remanded by holding that executions of mentally retarded defendants constituted cruel and unusual punishment prohibited by the Eight Amendment to the United States Constitution.  The Court supported its holding with the historical trend in state legislation favoring the elimination of death penalty as punishment for defendants with mental disabilities.  The Court also observed that, for mentally retarded individuals, capital punishment served neither retribution nor deterrence purposes due to such individual’s lessened mental culpability.

Related entries