Introduction
Standards provide the basis for evaluating and rationalizing events and arguments. The Supreme Court has the sole responsibility for determining constitutional matters. Part of this responsibility requires it to provide interpretations that align with prevailing societal standards as suggested by statistical methods. Therefore, and in chronological order, it is necessary to interrogate how the Supreme Courts’ position on capital punishments for minors has evolved. Thompson v. Oklahoma (1987) ; Stanford v. Kentucky (1989) and Roper v. Simmons (2005) , respectively, will provide the points of said evolution.
Thompson v. Oklahoma (1987)
The petitioner, then aged 15 was tried as an adult and convicted of murder in the first degree. The Court of Criminal Appeals of Oklahoma confirmed both the trial and the sentence. However, the US Supreme Court granted the petitioner reprieve in its review of the associated constitutional issues (Capital punishment in context, n.d). The 8 th amendment prohibits against cruel and unusual punishment because the framers of the constitution were keen to protect individuals against the extremes of state power. Consequently, the Court had to consider whether the 15-year-old petitioner’s death sentence was violative of the 8 th amendment prohibition.
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Arriving at the appropriate constitutional interpretation required the Court to adopt some guidelines. One of them was: “the evolving standards of decency that the progress of a maturing society” (Oyez, n.d). Presumably, this was in recognition of the differences in circumstances between the framing of the constitution and the time interval of the case. Specifically, the Court also relies on relevant jury determinations and legislative enactments. Using statistical analysis reports of the behavior of state legislatures and juries, the Supreme Court concluded that societal standards were against the execution of an offender who was less than 16 years old at the time of the offense (Capital punishment in context, n.d). Therefore, based on the Courts’ application of the above-mentioned guideline, it concluded that the execution of an offender under the age of 16 was not socially appropriate.
There was also the matter of constitutionality that required determination. Here, it concluded that special attention was constitutionally mandated by the 8 th amendment. This was informed by the risk that states could effectively establish capital punishment without age limits. Such a situation would render 15-year-old offenders liable to capital punishment (Oyez, n.d). Therefore, the Court determined that it was constitutionally appropriate to apply exceptional care to manage the risk of states implementing capital punishment laws that lack age limits.
The Courts’ decision was informed by constitutional provisions and the guideline on evolving societal standards on decency. Specifically, it noted that 8 th amendment provisions against cruel and unusual punishment applies to the states through the 14 th amendment and determined as unconstitutional the execution of a 15-year-old offender (Capital punishment in context, n.d). Also, the Court noted that such an execution would violate the: “evolving standards of decency that mark the progress of a maturing society” (Capital punishment in context, n.d). Therefore, the Court reversed the decisions of the trial court and the Court of Criminal Appeals of Oklahoma.
Stanford v. Kentucky (1989)
The 17-year-old offender was convicted by a jury trial in Kentucky for the receipt of stolen property, murder, and sodomy. He was sentenced to death under a state statute that allows capital punishment for certain juvenile offenders. On appeal, this case was consolidated with that of Wilkins v. Missouri . (Oyez, n.d) Both petitioners used their ages, 17 and 16 respectively, to contest the constitutionality of their imposed sentences. Therefore, both cases presented the Court with the opportunity to determine whether the death penalty for offenders under 18 years was violative of the 8 th amendment prohibitions.
The guideline on evolving standards of decency and maturity came to the fore once more along with the Courts’ use of statistical methods to make relevant calculations. In the latter case, the Court noted the lack of consensus on the imposition of capital punishment on offenders older than 15 years yet below 18 years (Oyez, n.d). Specifically, of the 37 states that permitted capital punishment, 12 outlaw the capital punishment of 17-year-olds while 15 other states forbade the capital punishment of 16-year-old offenders. Further, similar differences were reflected in national opinion polls, professional association studies, and interest group views. The execution of 16 and 17-year-old offenders lacked national consensus (Oyez, n.d). Equally, there was no societal agreement that made such sentences inappropriate or otherwise. Effectively, the lack of consensus meant that the Court could not declare capital punishment for 16 and 17-year-old offenders violative of the 8 th amendment provision against cruel and unusual punishment. Furthermore, it noted that such decisions could only be made at the local levels during the trials time interval (Oyez, n.d). Therefore, the Court left the implementation of the punishment to state preference.
Roper v. Simmons (2005)
The respondent was sentenced aged 17 and launched several state and federal appeals that benefitted from the US Supreme Court’s decision in Atkins v. Virginia . Therein, the Court ruled that the capital punishment of the mentally disabled was violative of their 14 th amendment rights (Capital punishment in context, n.d). This was because the majority of American society perceived such punishments as cruel and unusual, therefore, there was an advancement in the standards of decency and maturity of a society. Consequently, the Missouri Supreme Court chose to reconsider the respondents’ case (Capital punishment in context, n.d). The point of constitutional contention, in this case, rested on whether it was permissible to execute an offender who was over 15 but below 18 years.
The guideline on the evolution of standards of decency influenced the Court’s interpretation of the 8 th and 14 th amendments. In the preceding case, the Court implied that it was the lack of national consensus that limited its application of the guideline on societal decency and maturity. However, in Atkins v. Virginia , it concluded that there was a national consensus against the imposition of the death penalty through observing several trends (Capital punishment in context, n.d). The rejection of juvenile capital punishments in most states; the low frequency of its imposition in states with laws that allow juvenile capital punishment and an increase in those calling for its abolition. Though not statistical methods as defined in Thompson v Oklahoma , the Court found these trends to be sufficiently definite to affirm that society apportioned a reduced degree of criminal culpability to juveniles when compared with adult offenders (Oyez, n.d). Furthermore, the Court highlighted three differences between adult and juvenile offenders that supported the societal position. First, juveniles are immature and irresponsible in behavior, this reduces their moral reprehension. Second, because of their natural vulnerability and comparative lack of control, juveniles are relatively more susceptible to negative environmental influences, therefore, they deserve a greater degree of forgiveness. Third, adolescence is strongly associated with identity formation, weakening the argument that juveniles, even those who commit horrifying crimes, are incapable of redemption (Capital punishment in context, n.d). Therefore, the Court takes into account developments across American society to arrive at its decision.
The Court determined that societal standards of decency and maturity had evolved and the imposition of a juvenile death penalty was violative of the 8 th amendment. Therefore, it ruled that imposing juvenile capital punishment was a disproportionate punishment (Capital punishment in context, n.d). To affirm its position, the Court cited international opinion on the same, noting that America as the only country that permitted the practice. The Court used the international position to confirm the merits of its decision (Capital punishment in context, n.d). Therefore, the imposition of juvenile death sentences was declared unconstitutional in the ruling of the titled case.
Discussion and conclusion
The legal system should remain representative of societal values and these are subject to evolution. The criminal justice system exists to preserve said values and this means that the interpretation of the law might change to accommodate social realities. In Thompson v. Oklahoma (1987) , the issue was determining the constitutionality of executing a 15-year-old offender. In Stanford v. Kentucky (1989) , the contention was the constitutionality of executing those offenders who were above 15 years but below 18 years. In Roper v. Simmons (2005) , the issue was whether the execution of minors was violative of the constitution. The pattern of evolution started with the ruling that executing juveniles under 16 years was unconstitutional; it advanced to allowing states to decide whether to execute offenders older than 16 years but younger than 18 years and culminated in the ruling that prohibited all forms of juvenile executions. These cases are representative of the different stages of the Supreme Court’s evolution to remain consistent with societal views.
These observations suggest that social change precedes legal ones. Effectively, it is the evolution of society’s perception of juvenile capital punishment that has transformed the Supreme Court’s position on the execution of minors. Through its guidelines on evolving societal standards of decency and maturity along with statistical methods and its equivalents, the Supreme Court has been able to calculate and incorporate the appropriate levels of social change in its interpretation and application of the constitution.
References
Roper v. Simmons. (n.d). Capital punishment in context . Retrieved from https://capitalpunishmentincontext.org/resources/casesummaries/roper
Roper v. Simmons. (n.d). Oyez . Retrieved from https://www.oyez.org/cases/2004/03-633 .
Stanford v. Kentucky. (n.d). Capital punishment in context . Retrieved from https://capitalpunishmentincontext.org/resources/casesummaries/stanford
Stanford v. Kentucky. (n.d). Oyez . Retrieved from https://www.oyez.org/cases/1988/87-5765 .
Thompson v. Oklahoma. (n.d). Capital punishment in context . Retrieved from https://capitalpunishmentincontext.org/resources/casesummaries/thompson
Thompson v. Oklahoma. (n.d). Oyez . Retrieved from https://www.oyez.org/cases/1987/86-6169 .
