Thompson v. Oklahoma
Thompson v. Oklahoma
487 U.S. 815 (1988)
Facts and Procedural History:
Petitioner, when he was 15 years old, actively participated in a brutal murder. Because petitioner was a “child” as a matter of Oklahoma law, the District Attorney filed a statutory petition seeking to have him tried as an adult, which the trial court granted. He was then convicted and sentenced to death, and the Court of Criminal Appeals of Oklahoma affirmed.
Issue Presented to the Court:
Would the execution of a person who was under 16 years of age at the time of his offense violate the constitutional prohibition against the infliction of “cruel and unusual punishments?”
Outcome of the Case:
Being guided by the “evolving standards of decency that mark the progress of a maturing society,” the Court analyzes relevant legislative enactments and jury determinations. It finds that state statutes and the behavior of juries, as evidenced by statistical materials, support the conclusion that it is generally abhorrent to the conscience of the community to execute a person who was less than 16 years old at the time of his or her offense. That conclusion is also consistent with the views expressed by respected professional organizations, by other nations that share the Anglo-American heritage, and by the leading members of the Western European community.
The Court also concludes that because the Eighth Amendment requires special care in decisions that may lead to the imposition of the death penalty, there is a considerable risk that, in enacting a statute authorizing capital punishment for murder without setting any minimum age, and in separately providing that juvenile defendants may be treated as adults in some circumstances, the Oklahoma Legislature effectively renders 15-year-olds death eligible.
Accordingly, based on this evidence of a national consensus forbidding the imposition of capital punishment for crimes committed before the age of 16, the Court holds that petitioner may not be executed pursuant to a capital punishment statute that specifies no minimum age and, thus, violates the constitutional prohibition.