Introduction
The case of Christopher Simmons shook society in 1993 when underage teenagers executed a brutal premeditated killing and Simmons as the main perpetrator was found guilty and sentenced to the death penalty. After a series of appeals and changing public attitudes, the landmark Supreme Court case of Roper v. Simmons established that capital punishment could not be implemented on defendants younger than 18 at the time of committing a crime. The decision profoundly impacted public perception and the role of youth in the criminal justice system felt to this day
Defendant and Crime Background
In 1994, Christopher Simmons who was 17 at the time developed a plan with two of his friends to commit burglary and murder Shirley Crook, his neighbor. After one of his friends dropped out, the other two, Simmons and Benjamin broke into the home of Mrs. Crooks where they bound and blindfolded her. Later, they forced her into a vehicle and drove to a bridge at a nearby state park. The perpetrators tied the woman’s hands and feet with electrical wire and wrapped her whole face in duct tape, eventually throwing her off the bridge.
The next day, the woman’s husband returned from an overnight trip, finding the break-in reported the crime to the police. Simmons was openly bragging about committing burglary and murder which led to him being reported and arrested by the police. He waived his Miranda rights and right to an attorney, quickly confessing to the crime. Crook’s body was soon discovered, with the cause of death established as drowning (Legal Information Institute, n.d.).
Simmons was charged by the state with burglary, kidnapping, stealing, and first-degree murder, seeking the death penalty against him. He openly admitted to planning the events with his friends, believing that nothing would happen since they were all minors. The victim choice was not premeditated but seemingly chosen at random – with the plan of burglarizing, tying the victim, and throwing them off the bridge being the key to the plan. However, Simmons and Crook were involved in a car accident earlier, so when the two recognized each other, Simmons admitted to having confirmed his desire to commit murder (Legal Information Institute, n.d).
Due to the strong evidence of the case and Simmons openly collaborating with law enforcement on the details, he was quickly convicted, and the jury recommended a death sentence. Simmons continued to appeal the case citing ineffective counsel, his troubled background, and the mitigating factors of his age. Eventually, the Supreme Court of Missouri changed the sentencing to life imprisonment without parole, at which point the state appealed to the Supreme Court.
Supreme Court Case
While the Supreme Court does not usually take on criminal cases, this specific case in light of the national discussion touched on the issue of capital punishment for minors. A couple of years earlier in 2002, a similarly resonant case Atkins v. Virginia ruled that the execution of mentally retarted individuals was unconstitutional as it was viewed as cruel and unusual punishment. The Roper v. Simmons case was heard in 2004, and the Court voted 5-4 in arguing that capital punishment for minors or those that were minors at the time of the crime was unconstitutional as it violated the Eighth Amendment which protects against cruel and unusual punishment.
The Court once again cited ‘evolving standards of decency’ suggesting that scientific evidence indicates that adolescents lack maturity and mental capacity. Furthermore, a national consensus was coming to a position of supporting alternatives to capital punishment for adolescents, with the large majority of the states abolishing or delaying the practice. The dissenting opinion was written by Justice Scalia who criticized the national consensus issue and took examples from other countries but instead focused on the issue of the letter of the law and whether it would be ‘cruel and unusual punishment at the time of the ratification of the Bill of Rights.
Impact on Juvenile Justice
The Court established that juveniles were less culpable than adults prohibiting their classification as worst offenders that needed to face the ‘retribution and deterrence’ that capital punishment is essentially for. The three differences identified are 1) lack of maturity and underdeveloped responsibility, 2) vulnerability and susceptibility to negative influences, and 3) character and personality traits are in a transit state and less formed (Ingram, 2005).
The decision had a long-lasting impact on the juvenile criminal justice system. Previously, states took tough stances on crime, including that of juvenile crime through the concept of juvenile transfer or waiver where juveniles could be tried as adults, as it is allowed in all 50 states. Given the developmental differences highlighted by Roper, scholars, and policymakers have called upon reexamination of the juvenile justice system to shift its focus towards rehabilitation and mental development of children which is not possible in adult facilities. Both the capital punishment and the adult prison system are based on deterrence and retribution which has significant mitigating effects on adolescents tried and sentenced as adults (Fabian, 2010).
Admittedly, policy progress has been slow, but Roper v Simmons legally and historically does have implications for the juvenile justice system. The legal reasoning of the case does bring forward questions as to why some juvenile offenders (serial or felony crimes) are pushed to adult courts and treated differently than their peers. There are also discussions on abolishing life without parole sentences for juveniles as well. There are still issues in jurisdictions on how courts and legislators can respond to serious juvenile crime, with many states continuing to rely on waiver provisions to respond to actual and perceived threats of youth crime, even in the post-Roper era (Flynn, 2008).
Nevertheless, more recent findings by Benekos & Merlo (2016) identify that the juvenile criminal justice system has responded with more compassion in the decade since Roper. With progress in science and developmental psychology, there are better approaches to underage delinquents, particularly responding to children who have been exposed to violence (CEV) and recognizing the consequences of childhood trauma. The child-focused policies shift away from retribution but towards support and rehabilitation whenever possible while reducing and restricting excessive juvenile punishments.
References
Benekos, P. J., & Merlo, A. V. (2016). A Decade of change: Roper v. Simmons, defending childhood, and juvenile justice policy. Criminal Justice Policy Review, 30(1), 102–127. Web.
Fabian, J. M. (2010). Applying Roper v. Simmons in juvenile transfer and waiver proceedings. International Journal of Offender Therapy and Comparative Criminology, 55(5), 732–755. Web.
Flynn, E. H. (2008) Dismantling the felony-murder rule: Juvenile deterrence and retribution post-Rover v Simmons. University of Pennsylvania Law Review, 158(4), 1049-1076. Web.
Ingram, R. (2005). Death penalty for juveniles is cruel and unusual. Virginia Legislative Issue Brief, 40. Web.
Legal Information Institute. (n.d.). ROPER V. SIMMONS (03-633) 543 U.S. 551 (2005). Web.