the perpetrator. This will be discussed in the sections below. Punishments forbidden regardless of the crime In Wilkerson v. Utah, , the Supreme Court commented that drawing and quartering, public dissection, burning alive, or disembowelment constituted cruel and unusual punishment. Relying on Eighth Amendment case law Justice William O. Douglas stated in his Robinson v. California, concurrence opinion that "historic punishments that were cruel and unusual included "burning at the stake, crucifixion, breaking on the wheel" (In re Kemmler, 136 U. S. 436, 136 U. S. 446), quartering, the rack and thumbscrew (see Chambers v. Florida, 309 U. S. 227, 309 U. S. 237), and, in some circumstances, even solitary confinement (see In re Medley, 134 U. S. 160, 134 U. S. 167-168)." In Thompson v. Oklahoma, , the Supreme Court ruled that the death penalty constituted cruel and unusual punishment if the defendant is under age 16 when the crime was committed. Furthermore, in Roper v. Simmons, , the Court barred the executing of people who were under age 18 when the crime was committed. In Atkins v. Virginia, , the Court declared that executing people who are mentally handicapped constituted cruel and unusual punishment. Punishments forbidden for certain crimes The case of Weems v. United States, , marked the first time the Supreme Court exercised judicial review to overturn a criminal sentence as cruel and unusual. The Court overturned a punishment called cadena temporal, which mandated "hard and painful labor", shackling for the duration of incarceration, and permanent civil disabilities. This case is often viewed as establishing a principle of proportionality under the Eighth Amendment. However, others have written that "it is hard to view Weems as announcing a constitutional requirement of proportionality." In Trop v. Dulles, , the Supreme Court held that punishing a natural-born citizen for a crime by revoking his citizenship is unconstitutional, being "more primitive than torture" because it involved the "total destruction of the individual's status in organized society". In Robinson v. California, , the Court decided a California law authorizing a 90-day jail sentence for "be[ing] addicted to the use of narcotics" violated the Eighth Amendment, as narcotics addiction "is apparently an illness", and California was attempting to punish people based on the state of this illness, rather than for any specific act. The Court wrote: However, in Powell v. Texas, , the Court upheld a statute barring public intoxication by distinguishing