Napoleon Beazley

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Napoleon Beazley (August 5, 1976 – May 28, 2002) was a convicted murderer executed by lethal injection by the State of Texas for the murder of 63-year-old Texas businessman John Luttig in 1994. Beazley shot Luttig in his garage on April 19, 1994 in order to steal his family's Mercedes-Benz car. Beazley also shot at Luttig's wife, but he missed and she survived the assault by playing dead. Beazley carried out the crime with two accomplices, Cedrick and Donald Coleman, who later testified against him. Both are serving life sentences in prison.

Beazley's case is notable because he was 17 years, eight and one-half months old at the time of the offense and because his victim was the father of a Federal Judge, J. Michael Luttig. During his appeals to the U.S. Supreme Court, three of the nine justices recused themselves because of their personal ties to Judge Luttig, leaving six justices to review the case. Justice Antonin Scalia recused himself because Luttig had clerked for him, while Justices David Souter and Clarence Thomas recused themselves from the decision because Luttig had led the George H. W. Bush Administration's successful effort to gain U.S. Senate confirmation for them to the Supreme Court.

On August 13, 2001, the Court voted 3-3 on Beazley's request for a stay of execution, with the tie vote resulting in a rejection of the request.^[1] On May 28, 2002, the Court voted unanimously 6-0 to reject Beazley's request for a writ of habeas corpus.^[2] Scalia, Souter, and Thomas recused themselves in both votes.

Beazley's execution sparked a fierce debate between opponents and supporters of the death penalty, particularly with respect to juvenile offenders. Many organizations, such as Amnesty International, argued in favor of clemency due to his age (though Beazley at the time of offense was only 3½ months from his 18th birthday) and their opposition to the death penalty in general.^[3]

Others supported his sentence, pointing out that Beazley shot a 63-year old man simply to steal his car and his guilt was not in dispute (Beazley confessed to the crime). In addition, they pointed to a lack of mitigating factors. For example, Beazley had not grown up in a poor or abusive family.^[4] Many believed^[who?] that since he was only 3½ months from being a legal adult that his judgment was substantially the same as it would have been had he been 18, and scoffed at the notion that he was, in effect, a "child," although he couldn't vote and was subject to youth curfew laws at the time of his crime.

Beazley was one of the last juvenile offenders to be executed in the United States. In 2004, the Supreme Court (in Roper v. Simmons) banned the practice of executing offenders who were under of the age of 18 when they committed their crimes.