Criminal Defense

Penry v. Lynaugh - 492 U.S. 302 (1989)

The defense used in this case is temporary insanity. According to this defense, the courts must determine whether mens rae was lacking, which should then lead to the absolution of culpability off the defendant (Cole & Smith, 2009). The petitioner in Penry v. Lynanugh had been convicted for murder and rape by a Texas court having been determined to be mentally competent to be tried despite testimonies that he was mentally retarded, with the mental age equivalent to a six-year old individual. The defendant appealed directly to the Supreme Court against the execution of a mentally retarded person. The defendant presented psychiatric evidence demonstrating that he had suffered moderate retardation and insanity resulting in learning disabilities. According to the defense, the disabilities caused by the defendant’s mental retardation are relevant in any criminal proceedings as well as in the determination of criminal responsibility. The choice of punishments upon conviction of mentally sick individuals must take cognizance of this. In addition, the degree of the moral responsibility borne by mentally retarded individuals makes it constitutionally unnecessary to impose capital punishment, not least because the death penalty is reserved for convicted individuals who are morally guilty. Such guilt and moral realization of culpability is absent among mentally ill individuals and further that the Eighth Amendment prohibits the execution of individuals who are mentally retarded as inappropriate since its serves no reasonable penological purpose (Neubauer & Fradella, 2010).

The Supreme Court held that the jury ought to have heeded instructions that mental retardation comprised a mitigating circumstance in line with Woodson v. North Carolina. However, the court upheld the death penalty asserting that mental retardation did not on its own render the penalty an unusual and cruel punishment, Ford v. Wainwright. According to the ruling, the Eight Amendment bars the infliction unusual and cruel punishments that offend the evolving standards of societal decency expressed in the objective legislative enactments as well as decisions of juries. While common law as well as Ford v. Wainwright prohibits the punishment of idiots (mentally defective or retarded individuals), this was deemed to be not the case in Penry v. Lynaugh, since he had been found to be competent to stand trial in the initial trial and thus the insanity defense was defeated. Further, the court determined that with respect to capital punishment, it is necessary to bear in mind the record and character of the individual offenders as a part of the process of inflicting the sentence. There was no cause for the court to belief that the defendant lacked a complete understanding of the implications of the sentence imposes on him.