Atkins v. Virginia (2002)
Question: Does administration of the death penalty against individuals with mental retardation constitute cruel and unusual punishment (as prohibited by the Eighth Amendment)?
Holding: Yes; all punishments are excessive if they are not “graduated and proportioned to the offense.” The Court stated that although individuals with mental retardation will continue to be tried and sentenced, the punitive goals of capital punishment would not be realized in those cases.
Barefoot v. Estelle (1983)
Question: Does psychiatric testimony regarding predicting future dangerousness violate a defendant’s Eighth (cruel and unusual punishment) and Fourteenth (due process) Amendment rights?
Holding: No; the Court found that “the suggestion that no psychiatrist’s testimony may be presented with respect to a defendant’s future dangerousness is somewhat like asking us to disinvent the wheel.” They stated case law supports the use of expert testimony in predicting dangerousness, and the difficulty of making a decision regarding dangerousness does not render it inadmissible.
Estelle v. Smith (1981)
Question: Did the prosecution’s use of psychiatric testimony, at the sentencing phase of the respondent’s capital murder trial to establish his future dangerousness, violate his constitutional rights?
Holding: Yes; the Court determined that Smith’s Sixth Amendment right to assistance of counsel was violated. This decision was reached due to the defense counsel not being notified in advance of the examination’s intent (i.e., competence and assessment of future dangerousness) and denial of the assistance of counsel in making the decision of whether to participate in the evaluation.
Ford v. Wainwright (1986)
Question: Is it a violation of the Eighth Amendment to execute someone who is incompetent?
Holding: Yes; the Court stated that the “Eighth Amendment prohibits the State from inflicting the death penalty upon a prisoner who is insane.” Regarding Florida’s procedures of deciding if someone can be executed, the Court said they were not “adequate to afford a full and fair hearing.”
Panetti v. Quarterman (2007)
Question: What standard should be employed to determine someone’s competency to be executed?
Holding: Factual understanding alone is not sufficient to determine competency to be executed. The Court declined to establish a universal standard for competency to be executed. Rather, the Court opted to defer to mental health experts on this subject, noting that “expert evidence may clarify the extent to which severe delusions may render a subject’s perception of reality so distorted that he should be deemed incompetent.”
Roper v. Simmons (2005)
Question: Do the Eighth and Fourteenth Amendments prohibit the execution of juvenile offenders?
Holding: Yes; the Court held that the Eighth and Fourteenth Amendments forbid the imposition of the death penalty on offenders who were under the age of 18 when their crimes were committed.
Singleton v. Norris (2001)
Question: Is it constitutional for the State to involuntarily administer antipsychotic medication to a prisoner whose date of execution has been set? Similarly, is it constitutional for the State to execute a prisoner who has been involuntarily medicated under a Harper procedure?
Holding: The Eighth Circuit asserted that “the best medical interests of the prisoner must be determined without regard to whether there is a pending date of execution.” Thus, they held that the mandatory medication regimen, valid under the pendency of a stay of execution, does not become unconstitutional under Harper when an execution date is set. The Court further held that a State does not violate the Eighth Amendment as interpreted by Ford when it executes a prisoner who became incompetent during his long stay on death row, but who subsequently regained competency through appropriate medical care.