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At age 17, when he was still a junior in high school, Christopher Simmons planned and committed a capital murder. After he had turned 18, he was sentenced to death. He appealed his sentence, arguing that the Eighth Amendment, applicable to the states through the Fourteenth Amendment, prohibits the execution of a juvenile who was under 18 when he committed his crime. In Stanford v. Kentucky (1989), a divided Court rejected the proposition that the Constitution bars capital punishment for juvenile offenders between 15 and 19. In Roper, however, the Supreme Court held that 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. The Court affirmed the necessity of referring to "the evolving standards of decency that mark the progress of a maturing society" to determine which punishments are so disproportionate as to be "cruel and unusual." The Court held that standards of decency had evolved and now demonstrated that the execution of juveniles is cruel and unusual punishment. It concluded that the rejection of the juvenile death penalty in the majority of states; the infrequency of its use even where it remains on the books; and the consistency in the trend toward abolition of the practice provided sufficient evidence that today society views juveniles as categorically less culpable than the average criminal. In addition, the Court found the overwhelming weight of international opinion against the juvenile death penalty, although not controlling here, provided significant confirmation for the Court's determination that the penalty is disproportionate punishment for offenders under 18.
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