Thompson v. Oklahoma | |
---|---|
Argued November 9, 1987 Decided June 29, 1988 | |
Full case name | William Wayne Thompson v. State of Oklahoma |
Citations | 487 U.S. 815 ( more ) 108 S. Ct. 2687; 101 L. Ed. 2d 702; 1988 U.S. LEXIS 3028; 56 U.S.L.W. 4892 |
Case history | |
Prior | Defendant tried as an adult and convicted of murder of his brother-in-law, who had been abusing his ex-wife, who was Thompson's sister; was found guilty; and was sentenced to death. Appealed to Court of Criminal Appeals of Oklahoma, decision affirmed, 1986 OK CR 130, 724 P.2d 780. Appealed to U.S. Supreme Court, granted writ of certiorari , 479 U.S. 1084(1987). |
Holding | |
The Eighth and Fourteenth Amendments forbid imposition of the death penalty on offenders who were under the age of 16 when their crimes were committed. | |
Court membership | |
| |
Case opinions | |
Plurality | Stevens, joined by Brennan, Marshall, Blackmun |
Concurrence | O'Connor |
Dissent | Scalia, joined by Rehnquist, White |
Kennedy took no part in the consideration or decision of the case. | |
Laws applied | |
U.S. Const. amends. VIII, XIV |
Thompson v. Oklahoma, 487 U.S. 815 (1988), 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." [1] The holding in Thompson was expanded on by Roper v. Simmons (2005), where the Supreme Court extended the "evolving standards" rationale to those under 18 years old. [2]
William Wayne Thompson was a 15-year-old repeat offender from Grady County, Oklahoma. His sister, Vicki, was married to Charles Keene, who was accused of beating Vicki and William. Charles and Vicki had gotten married when Charles was 18 and Vicki was 15; Vicki says that the entire Thompson family was scared of Charles and that he had once ripped out all the telephone wires at the family home. [3] Vicki further says that Charles Keene once held her and Charles' son from the rooftop and threatened to kill him if Vicki left, and that the police could not be contacted because the police liked Charles and Charles was even rumored to be a police informant. [4] William and three other men (Tony Mann, Richard Jones, and Bobby Glass) then kidnapped Charles Keene on the night of January 23, 1983, in Amber, Oklahoma. Keene attempted to escape, running to neighbor John "Possum" Brown's door. He reportedly knocked on the door and screamed, "Possum, open the door, they're going to kill me". Brown opened the door, only to see four men dragging Keene from the door and beating him. When Brown called the police, the assailants grabbed Keene and fled.
Keene's body was found later in the nearby river, his body split throat to the abdomen. He had multiple bruises and two gunshot wounds, along with a concrete block tied to his legs. William was arrested after Vicki confessed to the police that William said that "he had taken care of him." The three other assailants were convicted of murder and sentenced to death; Richard Jones later had his sentence repealed. Bobby Glass was murdered in prison. After Thompson was arrested he underwent psychiatric evaluation to determine whether he was eligible to stand trial as an adult. He was found responsible for his deeds and convicted by the District Court of Grady County in Chickasha, Oklahoma. He was sentenced to death by the jury.
Thompson's attorneys first attempted to appeal the case on the basis of inflammatory photographs used by the prosecution to allegedly provoke the jury. Although the Oklahoma Court of Criminal Appeals found that two of the photographs should have been excluded from the trial, the overwhelming evidence meant that the case was affirmed by the appellate court. [5]
Due to Thompson's rapidly approaching execution, his attorneys subsequently filed his case with the Supreme Court, saying that the execution of a juvenile was unconstitutional under the Eighth Amendment's "Cruel and Unusual Punishment" clause.
The Court voted 5-3 in favor of Thompson (Justice Kennedy did not participate), holding that Thompson's execution would violate the Eighth Amendment to the United States Constitution as applied to the states through the Fourteenth Amendment. A plurality opinion by Justice Stevens noted the "evolving standards of decency that mark the progress of a maturing society" as a primary rationale for the decision [6] – an opinion that was strongly rejected in Justice Scalia's dissent. The plurality also noted that numerous U.S. jurisdictions and all industrialized Western nations had banned the execution of minors under 16 years of age. [7]
Thompson was later resentenced to life in prison with the possibility of parole. As of 2015, William Wayne Thompson and Tony Mann are still incarcerated. Thompson was granted parole in 2003, but that was later overturned by Oklahoma governor Brad Henry. His sister Vicki is currently campaigning to parole her brother.
The Eighth Amendment to the United States Constitution protects against imposing excessive bail, excessive fines, or cruel and unusual punishments. This amendment was adopted on December 15, 1791, along with the rest of the United States Bill of Rights. The amendment serves as a limitation upon the state or federal government to impose unduly harsh penalties on criminal defendants before and after a conviction. This limitation applies equally to the price for obtaining pretrial release and the punishment for crime after conviction. The phrases in this amendment originated in the English Bill of Rights of 1689.
In the United States, capital punishment is a legal penalty throughout the country at the federal level, in 27 states, and in American Samoa. It is also a legal penalty for some military offenses. Capital punishment has been abolished in 23 states and in the federal capital, Washington, D.C. It is usually applied for only the most serious crimes, such as aggravated murder. Although it is a legal penalty in 27 states, 20 of them have authority to execute death sentences, with the other 7, as well as the federal government and military, subject to moratoriums.
Capital punishment is a legal penalty in the U.S. state of Louisiana.
Capital punishment in Canada dates to Canada's earliest history, including its period as first a French then a British colony. From 1867 to the elimination of the death penalty for murder on July 26, 1976, 1,481 people had been sentenced to death, and 710 had been executed. Of those executed, 697 were men and 13 women. The only method used in Canada for capital punishment of civilians after the end of the French regime was hanging. The last execution in Canada was the double hanging of Arthur Lucas and Ronald Turpin on December 11, 1962, at Toronto's Don Jail. The National Defence Act prescribed the death penalty for certain military offences until 1999, although no military executions had been carried out since 1946.
Capital punishment was abolished in 2019 in New Hampshire for persons convicted of capital murder. It remains a legal penalty for crimes committed prior to May 30, 2019.
Roper v. Simmons, 543 U.S. 551 (2005), is a landmark decision by the Supreme Court of the United States in which the Court held that it is unconstitutional to impose capital punishment for crimes committed while under the age of 18. The 5–4 decision overruled Stanford v. Kentucky, in which the court had upheld execution of offenders at or above age 16, and overturned statutes in 25 states.
The People of the State of California v. Robert Page Anderson, 493 P.2d 880, 6 Cal. 3d 628, was a landmark case in the state of California that outlawed capital punishment for nine months until the enactment of a constitutional amendment reinstating it, Proposition 17.
Napoleon Beazley was an American convicted murderer executed by lethal injection by the State of Texas for the murder of 63-year-old businessman John Luttig in 1994.
Capital punishment is a legal penalty in the U.S. state of Texas for murder, and participation in a felony resulting in death if committed by an individual who has attained or is over the age of 18.
Dalton Prejean was one of 22 people in the United States executed for crimes committed as a juvenile prior to the decision Roper v. Simmons in 2005. He was tried, convicted, and executed in the electric chair in Louisiana for the murder of Louisiana State Police Trooper Donald Cleveland.
James Terry Roach was the second person to be executed by the state of South Carolina following the 1976 decision by the U.S. Supreme Court reauthorizing the use of capital punishment by the states. He was electrocuted on January 10, 1986, aged 25, nearly a year to the day following the electrocution of his accomplice, Joseph Carl Shaw, on January 11, 1985, at the Central Correctional Institution in Columbia. Roach was executed for a crime he committed at age 17.
Stanford v. Kentucky, 492 U.S. 361 (1989), 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.
Sean Richard Sellers was an American serial killer, one of 22 persons in the United States since the reinstatement of the death penalty in 1976 to be executed for a crime committed while under the age of 18, and the only one to have been executed for a crime committed under the age of 17. His case drew worldwide attention due to his age as well as his jailhouse conversion to Christianity and his claim that demonic possession made him innocent of his crimes.
Capital punishment for juveniles in the United States existed until March 2, 2005, when the U.S. Supreme Court ruled it unconstitutional in Roper v. Simmons. Prior to Roper, there were 71 people on death row in the United States for crimes committed as juveniles.
In the United States, life imprisonment is the most severe punishment provided by law in states with no valid capital punishment statute, and second-most in those with a valid statute. According to a 2013 study, 1 of every 2 000 inhabitants of the U.S. were imprisoned for life as of 2012.
Scott Allen Hain was the last person executed in the United States for crimes committed as a juvenile. Hain was executed by Oklahoma for a double murder–kidnapping he committed when he was 17 years old.
The United States Constitution contains several provisions related to criminal sentencing.
Capital punishment is a legal penalty in the U.S. state of Kentucky.
Johnny Frank Garrett was a death row prisoner executed by the State of Texas.
On February 21, 1994, in Jefferson County, Alabama, 37-year-old Vickie Deblieux was abducted, tortured, and murdered by a group of four youths while she was hitchhiking from Tennessee to her mother's house in Louisiana. Deblieux's body was discovered four days after she was killed, and the police later managed to arrest all four killers responsible.