After the Supreme Court ruling, Daryl Atkins' case continued. A jury later concluded his IQ had risen due to intellectual stimulation from his lawyers, making him eligible for execution under Virginia's standards. However, his execution was stayed after evidence of prosecutorial misconduct emerged, revealing that a co-defendant's testimony against him had been improperly coached. As a result of this misconduct, Atkins was ultimately re-sentenced to life imprisonment.

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In June 2002, the U.S. Supreme Court ruled in Atkins v. Virginia that executing individuals with intellectual disabilities constitutes 'cruel and unusual punishment' under the Eighth Amendment. The Court's decision was based on the reasoning that intellectual disability affects decision-making capabilities, which should be considered in criminal sentencing. This landmark ruling, which reversed a previous legal stance, was also influenced by a growing national consensus among state legislatures against such executions.

Supreme Court Ruling and Rationale in Atkins v. Virginia

Spielman, R. M., Jenkins, W. J., & Lovett, M. D. (2020, April 22). Psychology (2nd ed.). OpenStax. https://openstax.org/books/psychology-2e/pages/1-introduction

OpenStax Psychology (2nd ed.) Textbook

A key outcome of the Supreme Court's ruling in Atkins v. Virginia was that it granted individual states the authority to establish their own criteria for defining intellectual disability. This delegation of power led to different standards across the country for determining who is exempt from the death penalty on the basis of intellectual disability.

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