Roper v. Simmons
At the age of seventeen, Christopher Simmons committed a murder of which he was the instigator. The jury recommended the death penalty as three aggravating factors were proved by the State; thus, the trial judge imposed the death penalty (Roper v. Simmons, 2005). Later the decision was reconsidered, and Simmons was resentenced to life imprisonment without eligibility for probation, parole, or release.
To understand the logic of that decision, it is necessary to understand the reason for the verdict in Atkins v. Virginia (2002). In that case, it was argued that the Eight Amendment could be interpreted to protect the mentally disabled from the death penalty as it could be seen as a cruel and unusual punishment (Congressional Research Service, n.d.). It was concluded that despite previous practices, such as in the case of Penry v. Lynaugh (1989), it was possible to state that the standards of decency had evolved. The Court decided that there were objective markers of society’s new preferences and standards, such as the fact that only a minority of the US States permitted the death penalty for the mentally retarded. Even in those States, such a practice was extremely rare.
The case of Simmons was revised based on the same logic as in Atkins v. Virginia (2002). In 2005, at the time the case was considered, 30 States had already prohibited the juvenile death penalty; 12 states had totally abandoned it, while 18 had excluded juveniles from its reach. In the rest of the states, where the prosecution of children was legal, it was out of common. Moreover, the consistency of the trend was demonstrated by the US States in the years prior to the Roper v. Simmons case (2005). No States reinstated the death penalty for juveniles in the previous fifteen years, despite the Stanford v. Kentucky (1989) case that allowed it, but five States abandoned it. Summarizing the position of the Court was based on three main pillars. The first one is that the majority of States do not support the death penalty for juveniles; the second one is that even the minority that supports it does not enact it often. Finally, there is a clear trend of abandonment of this practice across the States.
According to the statement of the Supreme Court, there are three primary differences between people under 18 and adults. The first one considers “a lack of maturity and an underdeveloped sense of responsibility in juveniles” (Johnson v. Texas, 1993, para. 3). These qualities frequently lead to ill-considerate decisions and subsequent problems. Secondly, there is an issue of influence – it is much easier for underaged people to fall under adverse influence and outside pressures. The third point considers the character of teenagers – it is less formed than that of adults; therefore, the decisions of juveniles vary in a significantly broader range than that of adults. Moreover, each decision, in particular, characterizes them much less than it would characterize an adult.
Also, only the minority of adolescents that experiment with socially unacceptable actions, such as drug abuse or illegal activities, continue these patterns into the future. While previously, the Court recognized these factors in relation to people under 16; the new decision also included the category under 18. Overall, according to the Court, it is not enough that all of the factors are weighted against each other and accounted for within the judicial system. This is fact because the “brutality or cold-blooded nature of any particular crime would overpower mitigating arguments,” even despite the previously discussed arguments (Roper v. Simmons, 2005, para.3).
Miller v. Alabama
Evan Miller was 14 years old when he committed his crime. Before that, Miller had attempted suicide four times, used alcohol and other drugs regularly, and had been in and out of foster care (Miller v. Alabama, 2012). Miller killed his neighbor – Cole Cannon, after smoking marijuana with him and later robbing him. After that, to cover the evidence, Miller and his accomplice decided to burn the place. The case was considered in the adult court due to Miller’s previous juvenile offenses and perceived ‘mental maturity.’ Consequently, Miller was charged as an adult with a “mandatory minimum punishment of life without parole” (Miller v. Alabama, 2012, para 1).
In 2012 the United States Supreme Court held that mandatory life sentences without parole for juveniles are considered unconstitutional. The logic for that followed from the previous cases and continued them. In the case of Roper v. Simmons (2005), it was declared that the Eighth Amendment prohibits capital punishment for the underaged. In the Graham v. Florida (2010) case, it was concluded that the Eighth Amendment also bars a sentence of life without parole for a juvenile who committed any crime except for homicide. Moreover, in the Graham v. Florida (2010) case, the sentence of life without a possibility of parole was equalized to capital punishment, therefore, concluding that a mandatory life-without-parole sentence for underaged goes against the Eighth Amendment.
Specifically, the Court started with the same three main differences between underaged and mature people that were mentioned in the case of Roper v. Simmons (2005). The Court highlighted the fact that the same characteristics that differ children from adults make deterrence a less effective tool in the case of juveniles. At the same time, due to the previously mentioned facts, such as the statistics that only a tiny part of youngsters continue their illegal actions into adulthood, incapacitation is not relevant. It is not possible to say that society will always need protection from an underaged individual due to the fact that this individual cannot change, as change is integral for juveniles. This reasoning was applied only to the nonhomicide cases; however, there is no particular difference between crimes in terms of the mentioned factors; therefore, the same logic can be applied beyond nonhomicide cases.
Continuing the logic of the Court, in the Graham v. Florida case, it was concluded that life without a possibility of parole “share some characteristics with death sentences that are shared by no other sentences.” (2010, para 3.). For a youngster, such a sentence is more severe than for an adult, as the youngster will spend a more significant part of their life imprisoned. Moreover, both capital punishment and a lifelong prison sentence without a possibility of parole alter the rest of a person’s life irrevocably. The mandatory nature of the life-without-parole sentence removes responsibility from a sentence; therefore, some vital age, psychological, demographical, and background factors could be left unnoticed. That will equalize a teenager who has a history of abuse with an adult criminal, imposing a more severe punishment on the former one, as was demonstrated earlier. For these reasons, the Court decided to treat the death penalty and the life-without-parole sentence in the same way and decided that they cannot be applied as mandatory for juvenile offenders.
Conclusion
Overall, it seems that the two positions between the cases of Roper and Miller are not inconsistent. The conclusions reached in the case of Miller v. Alabama (2012) are built upon the ideas and concepts that were discussed and taken into account in the Roper v. Simmons (2005) case. The main arguments against the enaction of death punishment for juveniles were introduced and discussed within the Roper case. Using social, psychological, and legal arguments, the Court decided that a death sentence for people under eighteen violated the Eighth Amendment. In the end, Simmons received life imprisonment without eligibility for probation, parole, or release.
While within the Miller case, it is argued that both the death penalty and lifelong sentence without parole are equivalent and the latter one should not be mandatory, this does not contradict the Roper case. On the contrary, it uses the logic and arguments of the Roper case and adds the logic from the Graham case, which narrowed down the possibilities of application of the life-without-parole sentence in juveniles’ cases. Within the Miller case, the Court proves that the logic applied previously in the Graham case about nonhomicide crimes could be extended further and include murders as well. Furthermore, this case shows why capital punishment and life without parole can be equalized and that the latter is more harmful to juveniles than to adults. Therefore, the decisions of the two cases complement each other, and it is possible to say that the Miller case is built on the earlier Roper case.
References
Atkins v. Virginia, 536 U.S. 304 (2002). Web.
Congressional Research Service. (n.d.). Eighth Amendment. Constitution Annotated. Web.
Graham v. Florida, 560 U.S. 48 (2010). Web.
Johnson v. Texas, 509 U.S. 350 (1993). Web.
Miller v. Alabama, 567 U.S. 460 (2012). Web.
Penry v. Lynaugh, 492 U.S. 302 (1989). Web.
Roper v. Simmons, 543 U.S. 551 (2005). Web.
Stanford v. Kentucky, 492 U.S. 361 (1989). Web.