In the Atkins v. Virginia case, the U.S. Supreme Court contended that individuals under 18 cannot be executed.

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Atkins v. Virginia (2002) held that executing individuals with intellectual disabilities violates the Eighth Amendment's ban on cruel and unusual punishments, not specifically addressing the age of individuals under 18. The case concerning the execution of individuals under 18 was Roper v. Simmons (2005).

In the Atkins V