The Unkindness of Fate: Why Atkins v. Virginia Warrants an Extension to Capital Defendants with a Cluster B Personality Disorder
By Olivia Meme** Full Article. I. Introduction. Daryl Renard Atkins never finished high school.[1] His trouble with academics began when he was held back in the second grade and continued throughout elementary and middle school, where he maintained a “D” grade average.[2] His middle school transcripts noted “he did not meet the requirements for promotion to high school.”[3] Socially, Atkins was described as a “follower” whose “limited intellect would result in ‘reduced judgments and reduced understanding of the world in general around him compared to others.’”[4] He accrued twenty-one felony convictions between the ages of thirteen and eighteen.[5] Atkins’s former teachers described him as having “a constant problem with authority, tardiness, loitering, [and] disciplinary problems.”[6] After repeating the tenth grade, Atkins was placed in a classroom meant for “slow learners,” with…