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Roper v. Simmons

Supreme Court of the United States · 2005 · Criminal Procedure

Criminal ProcedureConstitutional LawEighth Amendmentdeath penaltyjuvenile offenderscruel and unusual punishmentEighth AmendmentFourteenth Amendment

Facts

At age 17, Christopher Simmons planned and carried out the murder of Shirley Crook with a younger accomplice. Simmons had discussed beforehand that he wanted to commit burglary and murder and said they could "get away with it" because they were minors. After breaking into Crook's home, Simmons and his accomplice bound her, drove her to a state park, and took her to a railroad trestle over the Meramec River. Simmons was later tried after he turned 18 and received a death sentence for a crime committed while still under 18.

Issue

Does the Eighth and Fourteenth Amendments permit a State to impose the death penalty on an offender who was older than 15 but younger than 18 when he committed a capital crime? More specifically, may an offender who was under 18 at the time of the offense be executed consistent with the Constitution?

Rule

The Eighth and Fourteenth Amendments forbid imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed. Juvenile offenders under 18 are categorically less culpable than adult offenders, and the death penalty is disproportionate punishment for that class.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Tulsa, 17-year-old Mateo Cruz carefully planned a robbery-murder and left behind notes showing weeks of preparation. He was arrested two days later, turned 18 while awaiting trial, and an Oklahoma prosecutor seeks a death sentence because the crime was especially calculated.

If Mateo is convicted of capital murder, is the death sentence constitutional?

Explanation. The controlling rule is categorical: the Eighth and Fourteenth Amendments forbid imposition of the death penalty on offenders who were under 18 when their crimes were committed. The offender's age at trial or sentencing does not matter. Even extreme planning or brutality cannot overcome the constitutional bar for this class of offenders.