Landmark Court Cases
These are a few significant cases that made it to the Supreme Court, and helped shape a modern interpretation of the 8th amendment.
Waters-Pierce Oil Co. VS TexasYear: 1900
Summary of case: The Waters-Pierce Oil Co. was charged by Attorney General Martin M. Crane for breaking the Texas antitrust law. Crane stated that the Waters-Pierce was a party to the Standard Oil of New Jersey trust agreement. The company was sentenced to a penalty of revocation of the company's charter and cancellation of its permit to do business in Texas, along with a fine of over $1.6 million dollars, which was upheld by the state's appeal courts. Early in 1900 the United States Supreme Court upheld the state courts' rulings. However, Water-Pierce declared in their counter suit that the large fine violated the excessive fines clause of the eighth amendment. Court Decision: The court disagreed with the claim, stating that the court "...cannot interfere with state legislation in fixing fines, or judicial action in imposing them, unless so grossly excessive as to amount to deprivation of property without due process of law... this Court will not hold that the fine is so excessive as to amount to deprivation of property without due process of law where it appears that the business was extensive and profitable during the period of violation, and that the corporation has over $40,000,000 of assets and has declared dividends amounting to several hundred percent." Effect on the 8th amendment: This case settled a standard for judging whether or not a fine is "excessive", which would be if the fine is "...so grossly excessive as to amount to deprivation of property without due process of law..." |
Henry Clay Pierce, founder and president of the Water-Pierce CO.
^logo of the Waters-Pierce Oil Co.
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^Justice Joseph McKenna, one of the Justices of the Supreme Court at the time.
^Justice Edward White, also one of the Justices of the Supreme Court at the time. He later becomes Chief Justice.
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Weems VS United StatesYear: 1910
Summary of case: Paula Weems was an officer of the Bureau of Coast Guard and Transportation of the United States Government of the Philippines Islands. He was convicted of exaggerating official records which led to the defrauding of the government of 616 pesos. His punishment included 15 years of hard labor in prison, having to constantly be in chains, the loss of all political rights in prison, permanent surveillance after release, and a fine of 4000 pesetas. He appealed his case to the Supreme Court, declaring that it breached his constitutional right from cruel and unusual punishments. Court Decision: The Supreme Court's final decision was that Weems' punishment is indeed "cruel and unusual"; however, there were slight controversies between the justices over the reason "why". Justice McKenna chose to read the 8th amendment in a broader fashion, thus noting that "...it is a precept of justice that punishment for crime should be graduated and proportioned to offense" and that the punishment was “cruel in its excess of imprisonment and that which accompanies and follows imprisonment. It is unusual in its character. Its punishments come under the condemnation of the Bill of Rights, both on account of their degree and kind.” On the other hand, Justice White had the dissenting opinion that McKenna's new interpretation was “repugnant to the natural import of the language employed in the clause, and which interpretation curtails the legislative power of Congress to define and punish crime by asserting a right of judicial supervision over the exertion of that power, in disregard of the distinction between the legislative and judicial department of the government.” In his studies of the amendment, he found "no basis for any assumed role of apportionment to assure that the punishment fit the crime." Despite this, Justice White admitted that the cruel and punishments clause left some room for courts to apply the Constitution to the changing needs of people, concluding that Weems' punishment may be considered "cruel and unusual". Effect on the 8th amendment: This case established the "principle of proportionality" when punishments are handed down. |
Gregg VS GeorgiaYear: 1976
Summary of case: Troy Gregg was found guilty of the armed robbery and murder of two men, and was therefore sentenced to death. However, he appealed his case claiming that in Furman VS Georgia of 1972, the Supreme Court had already ruled the death penalty as "cruel and unusual" punishment, which would make the death penalty unconstitutional. Court Decision: The Supreme Court denied this, noting that there was no standard for which the death penalty can be given at the time. As Justice Stewart described it, the death penalty was "...cruel and unusual the same way being struck by a lightning bolt is cruel and unusual." This means that the court had decided that it was the random way of which the death penalty was applied that made the death penalty unconstitutional, and not the death penalty itself; therefore, a moratorium, or a temporary ban, was placed on the death penalty. However, in this case, the Court found that Georgia had a "judicious" and "careful" system for applying the death penalty, and Gregg had gone through all due process of the court system still wielding results of the "aggravating circumstances" necessary to apply the death penalty. The Court concluded that no violations of the 8th amendment had been made. Effect on the 8th amendment: The case Furman VS Georgia of 1972 essentially barred the death penalty; however, in Gregg VS Georgia, the Court reaffirmed the constitutionality of the death penalty for the first time. |
^Troy Leon Gregg. He later escaped from prison.
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^Daryl Atkins. He was let off of the death penalty because he had a low IQ.
^Daryl Atkins and William Jones (his friend) captured on a bank camera with Eric Nesbitt between them.
Here's a link to a recent The New York Times article about the prosecutorial misconduct linked to this case:
http://www.nytimes.com/2008/01/19/us/19death.html?pagewanted=all&_r=0 |
Atkins VS VirginiaYear: 1998
Summary of case: In the evening of August 16, 1998, Daryl Atkins and a friend robbed and shot Eric Nesbitt. Atkins was found guilty of abduction, armed robbery, and capital murder; consequently, he was sentenced to death despite the testimony of Dr. Evan Nelson, who confirmed that Atkins had mild mental retardation. This decision was upheld by the Virginia Supreme Court, following the example the US Supreme Court had set when dealing with the Penry VS Lynaugh case. Later, Atkins repealed his case to the Supreme Court on the grounds that the execution of a person with mental disability is unconstitutional. Court Decision: The US Supreme Court held that sentencing a person with mental retardation violates the eighth amendment. They explained that at the time of the Penry ruling, only two states had passed statutes banning the execution of the mentally retarded; however, since then, an additional 16 states had enacted such statutes. Justice Stevens wrote, “It is not so much the number of these States that is significant, but the consistency of the direction of change" and that punishment prohibited by the eighth amendment are judged by the "evolving standards of decency that mark the progress of a maturing society." Therefore, the fact that the execution of mental retardants has rarely been used support the summary of Justice Stevens, which states that "the practice, therefore, has become truly unusual, and it is fair to say that a national consensus has developed against it." Effect on the 8th amendment: This case allowed Supreme Court to rule that it is against the cruel and unusual punishments clause of the 8th amendment to execute someone with a mental disorder. |