Atkins v. Virginia - Intellectual Disability and the Death Penalty

        In 2002, Daryl Renard Atkins, a man who was convicted of abduction, armed robbery, and capital murder, presented a major challenge to the United States Supreme Court due to his intellectual disability. In the penalty phase of his trial, Atkins was sentenced to death by the Circuit Court of York in Virginia based on the 1989 ruling for Penry v. Lynaugh, which upheld that capital punishment for the intellectually disabled was constitutional under the Eighth Amendment.
         Following this initial verdict, the case was taken to the Supreme Court of Virginia where Atkins' death sentence was to be altered because the first verdict was rejected. As a result, the case was re-heard at the York County Circuit Court in Virginia, where the death penalty was still maintained as an adequate punishment despite the revelation that Atkins had an IQ score of just 59. According to the American Association on Mental Retardation, intellectual disability can be determined through an IQ score of 70 or below, although this was not enough to reverse Atkins' verdict. Months later, the case was heard again at the Virginia Supreme Court and the death penalty was still upheld. However, the possibility for a different fate for Atkins arose when two justices dissented and claimed that the death penalty was an improper form of punishment for the intellectually disabled.
         Due to the introduction of these ideas, the case was taken to the Supreme Court, where a 6-3 decision ruled that the execution of mentally disabled criminals was "cruel and unusual punishment," and therefore a violation of the Eighth Amendment. Penry v. Lynaugh was overruled, however, Atkins' planned execution was not immediately lifted. In fact, at the circuit court level, he was convicted for a third time because his mental disability was not adequately proven in the eyes of the court. A struggle ensued to prove his disability as the Virginian Supreme Court remanded the case to the circuit court and he was proven mentally competent in 2005. He was almost executed until his case was appealed. The Virginia Supreme Court then reversed the verdict determined at the circuit level by explaining that improper evidence had been proposed at the start of the trial and the prosecution expert witness was unqualified to take on the case.
        Finally, in 2008, the case was heard only one more time at the York County Circuit Court and Atkins' sentence was declared as life imprisonment without parole instead of the death penalty. It becomes apparent that the struggle to reverse the Penry v. Lynaugh decisions is a result of how often and how greatly intellectual disabilities are misunderstood. People with mental disabilities are at a much greater risk to receive capital punishment, however, this important ruling now calls upon states to work more closely under the Constitutional mandate to develop new processes, procedures, and definitions of mental disability that comply with the ever-changing standards set for offenders affected by such disabilities. Ever since, more states have been compelled to prohibit the death penalty for the mentally disabled, which affirms the view that these criminals are less culpable than an ordinary criminal. 



Sources:
https://www.timetoast.com/timelines/atkins-v-virginia
oyez.org/cases/2001/00-8452
https://www.law.cornell.edu/supremecourt/text/536/304
https://www.apa.org/about/offices/ogc/amicus/penry