Stanford v. Kentucky
Encyclopedia
Stanford v. Kentucky, , was a United States
Supreme Court case that sanctioned the imposition of the death penalty on offenders who were at least 16 years of age at the time of the crime. This decision came one year after Thompson v. Oklahoma
, in which the Court had held that a 15-year-old offender could not be executed because to do so would constitute cruel and unusual punishment. In 2003, the Governor of Kentucky
Paul E. Patton
commuted the death sentence of Kevin Stanford, an action followed by the Supreme Court two years later in Roper v. Simmons
overruling Stanford and holding that all juvenile offenders are exempt from the death penalty.
. Kevin Stanford committed the murder on January 7, 1981, when he was approximately 17 years and 4 months of age. Stanford and his accomplice repeatedly raped and sodomized Poore during and after their commission of a robbery at a gas station where she worked as an attendant. They then drove her to a secluded area near the station, where Stanford shot her pointblank in the face and then in the back of her head. The proceeds from the robbery were roughly 300 cartons of cigarettes, two gallons of fuel, and a small amount of cash.
After Stanford's arrest, a Kentucky juvenile court conducted hearings to determine whether he should be transferred for trial as an adult
, and, stressing the seriousness of his offenses and his long history of past delinquency, found that certification for trial as an adult to be in the best interest of Stanford and the community.
Stanford was convicted of murder, first-degree sodomy, first-degree robbery, and receiving stolen property, and was sentenced to death and 45 years in prison. The Kentucky Supreme Court affirmed the death sentence, rejecting Stanford's "deman[d] that he has a constitutional right to treatment." Finding that the record clearly demonstrated that "there was no program or treatment appropriate for the appellant in the juvenile justice system," the court held that the juvenile court did not err in certifying Stanford for trial as an adult. The court also stated that Stanford's "age and the possibility that he might be rehabilitated were mitigating factors appropriately left to the consideration of the jury that tried him."
, and the West Virginia Council of Churches. Briefs supporting the affirmation of the capital sentence were filed by the Attorney General of Kentucky, and a number of attorneys general from other states.
In both cases, briefs of amici curiae were put forth by the American Bar Association
, the American Society for Adolescent Psychiatry, the International Human Rights Group, and Amnesty International
.
Arguments in the defense of petitioners Stanford and Wilkins (see below) were that the application of capital punishment upon defendants who were minors at the time of the offense was unconstitutional because it violated the prohibition of "cruel and unusual punishment" under the Eighth Amendment to the United States Constitution.
(1976).
Justice Sandra Day O'Connor, although agreeing that no national consensus forbade the imposition of capital punishment on 16- or 17-year-old murderers, concluded that the court has a constitutional obligation to conduct proportionality analysis, (citing Penry v. Lynaugh) and should consider age-based statutory classifications that are relevant to that analysis. .
Justice Brennan filed a dissenting opinion, in which he was joined by Justices Marshall, Blackmun, and Stevens.
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
Supreme Court case that sanctioned the imposition of the death penalty on offenders who were at least 16 years of age at the time of the crime. This decision came one year after Thompson v. Oklahoma
Thompson v. Oklahoma
Thompson v. Oklahoma, 487 U.S. 815 , was the first case since the moratorium on capital punishment was lifted in the United States in which the U.S. Supreme Court overturned the death sentence of a minor on grounds of "cruel and unusual punishment."...
, in which the Court had held that a 15-year-old offender could not be executed because to do so would constitute cruel and unusual punishment. In 2003, the Governor of Kentucky
Governor of Kentucky
The Governor of the Commonwealth of Kentucky is the head of the executive branch of government in the U.S. state of Kentucky. Fifty-six men and one woman have served as Governor of Kentucky. The governor's term is four years in length; since 1992, incumbents have been able to seek re-election once...
Paul E. Patton
Paul E. Patton
Paul Edward Patton was the 59th governor of Kentucky, serving from 1995 to 2003. Because of a 1992 amendment to the Kentucky Constitution, he was the first governor eligible to succeed himself in office since James Garrard in 1800...
commuted the death sentence of Kevin Stanford, an action followed by the Supreme Court two years later in Roper v. Simmons
Roper v. Simmons
Roper v. Simmons, was a decision in which the Supreme Court of the United States held that it is unconstitutional to impose capital punishment for crimes committed while under the age of 18. The 5-4 decision overruled the Court's prior ruling upholding such sentences on offenders above or at the...
overruling Stanford and holding that all juvenile offenders are exempt from the death penalty.
Background
The case involved the shooting death of 20-year-old Barbel Poore in Jefferson County, KentuckyJefferson County, Kentucky
As of the census of 2000, there were 693,604 people, 287,012 households, and 183,113 families residing in the county. The population density was . There were 305,835 housing units at an average density of...
. Kevin Stanford committed the murder on January 7, 1981, when he was approximately 17 years and 4 months of age. Stanford and his accomplice repeatedly raped and sodomized Poore during and after their commission of a robbery at a gas station where she worked as an attendant. They then drove her to a secluded area near the station, where Stanford shot her pointblank in the face and then in the back of her head. The proceeds from the robbery were roughly 300 cartons of cigarettes, two gallons of fuel, and a small amount of cash.
After Stanford's arrest, a Kentucky juvenile court conducted hearings to determine whether he should be transferred for trial as an adult
Trial as an adult
Trial as an adult is a term used to describe a situation when a juvenile offender is tried as if they were an adult.Where specific protections exist for juvenile offenders , these protections may be waived.Sanctions handed down are often harsher than those imposed on...
, and, stressing the seriousness of his offenses and his long history of past delinquency, found that certification for trial as an adult to be in the best interest of Stanford and the community.
Stanford was convicted of murder, first-degree sodomy, first-degree robbery, and receiving stolen property, and was sentenced to death and 45 years in prison. The Kentucky Supreme Court affirmed the death sentence, rejecting Stanford's "deman[d] that he has a constitutional right to treatment." Finding that the record clearly demonstrated that "there was no program or treatment appropriate for the appellant in the juvenile justice system," the court held that the juvenile court did not err in certifying Stanford for trial as an adult. The court also stated that Stanford's "age and the possibility that he might be rehabilitated were mitigating factors appropriately left to the consideration of the jury that tried him."
Oral Arguments Before the United States Supreme Court
Oral arguments were heard 26 March 1989. Prior to the hearing, briefs of amici curiae pushing for reversal were filed by the American Baptist Churches, the Child Welfare League of AmericaChild Welfare League of America
The Child Welfare League of America or CWLA is the oldest child welfare organization in the United States. The organization's primary objective is to "Make Children a National Priority...
, and the West Virginia Council of Churches. Briefs supporting the affirmation of the capital sentence were filed by the Attorney General of Kentucky, and a number of attorneys general from other states.
In both cases, briefs of amici curiae were put forth by the American Bar Association
American Bar Association
The American Bar Association , founded August 21, 1878, is a voluntary bar association of lawyers and law students, which is not specific to any jurisdiction in the United States. The ABA's most important stated activities are the setting of academic standards for law schools, and the formulation...
, the American Society for Adolescent Psychiatry, the International Human Rights Group, and Amnesty International
Amnesty International
Amnesty International is an international non-governmental organisation whose stated mission is "to conduct research and generate action to prevent and end grave abuses of human rights, and to demand justice for those whose rights have been violated."Following a publication of Peter Benenson's...
.
Arguments in the defense of petitioners Stanford and Wilkins (see below) were that the application of capital punishment upon defendants who were minors at the time of the offense was unconstitutional because it violated the prohibition of "cruel and unusual punishment" under the Eighth Amendment to the United States Constitution.
Opinion of the Supreme Court
In both Stanford v. Kentucky, and the parallel case Wilkins v. Missouri, the Supreme Court affirmed the capital punishments handed down in lower courts. Writing for the majority, Justice Antonin Scalia wrote that neither Stanford or Wilkins asserted that the punishment was cruel or unusual at the time the Bill of Rights was adopted (common law at the time set the incapacity to commit a felony at age 14), and so both petitioners were left to argue that capital punishment for minors older than 14, was contrary to "the evolving standards of decency". This expanse in the review of the Eighth Amendment was not granted in this decision, and Scalia went on to cite precedent limits set in Gregg v. GeorgiaGregg v. Georgia
Gregg v. Georgia, Proffitt v. Florida, Jurek v. Texas, Woodson v. North Carolina, and Roberts v. Louisiana, 428 U.S. 153 , reaffirmed the United States Supreme Court's acceptance of the use of the death penalty in the United States, upholding, in particular, the death sentence imposed on Troy Leon...
(1976).
"We discern neither a historical nor a modern societal consensus forbidding the imposition of capital punishment on any person who murders at 16 or 17 years of age. Accordingly, we conclude that such punishment does not offend the Eighth Amendment's prohibition against cruel and unusual punishment. [...] and to mean that as the dissent means it, i.e., that it is for us to judge, not on the basis of what we perceive the Eighth Amendment originally prohibited, or on the basis of what we perceive the society through its democratic processes now overwhelmingly disapproves, but on the basis of what we think "proportionate" and "measurably contributory to acceptable goals of punishment" -- to say and mean that, is to replace judges of the law with a committee of philosopher-kings."
Justice Sandra Day O'Connor, although agreeing that no national consensus forbade the imposition of capital punishment on 16- or 17-year-old murderers, concluded that the court has a constitutional obligation to conduct proportionality analysis, (citing Penry v. Lynaugh) and should consider age-based statutory classifications that are relevant to that analysis. .
Justice Brennan filed a dissenting opinion, in which he was joined by Justices Marshall, Blackmun, and Stevens.
See also
- List of United States Supreme Court cases, volume 492
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court