Roper v. Simmons

Roper v. Simmons was a landmark case heard in the Supreme Court of Missouri and the Supreme Court of the United States that changed how juveniles are treated in the US criminal justice system. In Roper v. Simmons, the US Supreme Court affirmed Missouri’s highest court in holding it is unconstitutional to execute a defendant for a crime committed when they were younger than the age of eighteen. The case continues to impact the way US courts consider the treatment of juveniles in the criminal justice system.

On September 9, 1993, Shirley Crook, a resident of an area near Fenton, Missouri, was reported missing by her husband. That afternoon her body was identified by a medical examiner after two fishermen found it floating in the Meramec River. Police received information that Christopher Simmons, who was seventeen at the time, had bragged to friends about murdering Crook. Simmons was arrested the next day. He waived his Miranda rights against self-incrimination and confessed to the murder. Further questioning revealed Simmons had discussed committing a burglary and murder with two friends. Simmons said he believed they would be able to “get away with it” because they were juveniles.

Simmons confessed that in the early hours of September 9, he and another teen, Charles Benjamin, entered Crook’s home. They bound her hands, put tape over her eyes and mouth, and used her minivan to drive her to Castlewood State Park in St. Louis County. They stopped at a railroad trestle on the Meramec River, tied her hands and feet, and pushed her into the river.

Simmons was tried in Jefferson County for first-degree murder, burglary, kidnapping, and stealing. He was found guilty of first-degree murder, and the circuit court sentenced him to death. (In a separate trial, Benjamin was sentenced to life in prison.) Simmons appealed to the Supreme Court of Missouri in 1997, arguing his confession was involuntary, media coverage had affected his right to a fair trial, the jury was improperly selected and instructed, and he had received ineffective counsel. The court upheld Simmons’s conviction and death sentence. Simmons then filed a petition for a writ of habeas corpus in US district court, which was denied. Simmons appealed to the US Court of Appeals for the Eighth Circuit, which affirmed the denial of habeas relief.

In 2002 the Supreme Court of Missouri again reviewed Simmons’s death sentence when the state asked it to set his execution date. That same year the US Supreme Court held in Atkins v. Virginia that, based on evolving standards of decency in the United States, the execution of intellectually disabled offenders constituted cruel and unusual punishment in violation of the Eighth Amendment to the US Constitution. The Supreme Court of Missouri, believing the reasoning in Atkins v. Virginia also applied to juveniles, held in 2003 that the execution of offenders who committed their crimes as juveniles also violated the Eighth Amendment. The court resentenced Simmons to life in prison without parole. The US Supreme Court affirmed this decision in 2005. Both courts emphasized that most states forbade executions of persons under the age of eighteen, and that the evolving standard of decency as reflected in the decreasing frequency of death sentences for juveniles made their execution cruel and unusual punishment.

Roper v. Simmons is significant because it halted the execution of juveniles. At the time it was decided, twenty states allowed executions for crimes committed by individuals under the age of eighteen. Seventy-two people were taken off death row as a result of Roper v. Simmons. The case also paved the way for courts to reconsider whether juveniles were as culpable as adults committing the same crimes. Subsequent US Supreme Court decisions in Graham v. Florida (2010) and Miller v. Alabama (2012) held that juveniles cannot be sentenced to life in prison without parole, and that mandatory sentences of life without parole are unconstitutional for juveniles—the judge or jury must consider the individual culpability of defendants under the age of eighteen in deciding whether that person should be forever denied parole.