The US Supreme Court on Thursday rejected Alabama's attempt to overturn a lower court finding that Joseph Clifton Smith, a death row inmate, is intellectually disabled and therefore ineligible for execution under the Constitution.
In a terse, single-sentence unsigned order, the justices dismissed the state's petition in Hamm v Smith without ruling on the merits. The move effectively abandoned the court's earlier decision to hear Alabama's appeal, leaving intact the federal judge's determination that Smith cannot be executed.
The case centered on how courts should weigh multiple IQ test scores when determining intellectual disability. Smith's five IQ tests ranged from 78 to 72, clustering around the crucial 70-point threshold below which Alabama law prohibits execution. A federal judge in the 11th Circuit found that Smith's lowest score could fall as low as 69 when accounting for measurement error, and that even his higher scores, combined with evidence of severe adaptive deficits, established intellectual disability.
Alabama objected to this approach, arguing that courts should place greater weight on the cumulative scores above 70 rather than relying heavily on the lowest result and supplementary evidence. The state appealed twice to the Supreme Court, framing the case as a matter of proper legal methodology for assessing intellectual capacity.
Had the justices sided with Alabama, the ruling could have narrowed pathways for judicial consideration of evidence beyond IQ test results. The consequence would likely have been more executions among people with intellectual disabilities, a group already overrepresented on death row.
Justices Sonia Sotomayor and Ketanji Brown Jackson concurred in dismissing the case, while Clarence Thomas and Samuel Alito dissented. Chief Justice John Roberts and Neil Gorsuch joined Alito's partial dissent.
In a concurring opinion, Sotomayor suggested the lower court's finding that Smith is intellectually disabled was sound and that the Supreme Court lacks expertise to issue sweeping guidance on IQ score methodology. She left open the possibility of future intervention if disputes among states or lower courts warranted clearer direction.
The decision rests on a foundational 2002 Supreme Court precedent holding that executing intellectually disabled people violates the Eighth Amendment's prohibition on cruel and unusual punishment. Subsequent rulings in 2014 and 2017 empowered courts to examine IQ scores near 70 alongside other evidence of cognitive and adaptive deficits.
Smith's case illustrates the complexity. School records identified him as educationally mentally disabled in seventh grade. Court documents cited his inability to maintain a bank account and difficulties purchasing groceries as examples of adaptive deficits that manifested before age 18, meeting Alabama's legal standard for intellectual disability despite some IQ scores above the cutoff.
The Trump administration, which has opposed restrictions on capital punishment, backed Alabama's position in the case.
Author James Rodriguez: "The Supreme Court's quiet exit from this fight preserves a lifeline for defendants caught in the murky zone between test scores and real-world function, but the underlying question of how courts should weigh evidence of disability remains unsettled and inviting future conflict."
Comments