Simmon's execution. During this time the U.S. Supreme Court decided Atkins v. Virginia ruled that executing the mentally disabled violated the Eighth and fourteenth Amendment prohibitions on cruel and unusual punishment because a majority of Americans found it cruel and unusual. This made the Missouri Supreme Court decide to reconsider Simmons' case. Using the reasoning from the Atkins case, the Missouri court decided that the U.S. Supreme Court's 1989 decision in Stanford v. Kentucky, which held that executing minors was not unconstitutional, was no longer valid. The opinion in Stanford v. Kentucky had relied on a finding that a majority of Americans did not consider the execution of minors to be cruel and unusual. The Missouri court, citing
