The United States Supreme Court has decided to leave in place a lower court ruling in the ongoing case of Hamm v. Smith, concerning Joseph Smith, an Alabama death-row inmate. In a succinct one-sentence order, the Supreme Court dismissed Alabama’s petition by stating that it was “improvidently granted,” thus supporting the U.S. Court of Appeals for the 11th Circuit’s decision to overturn Smith’s execution based on his intellectual disability. The full order is available online.
Smith’s case has attracted attention due to its implications for the interpretation of intellectual disability in capital punishment cases, a key issue highlighted by the precedent-setting decision in Atkins v. Virginia, which prohibits executing individuals who are intellectually disabled as per the Eighth Amendment.
The crux of Alabama’s argument was that the appeals court overly emphasized individual IQ results rather than considering the cumulative scores, which suggested Smith might not be intellectually disabled. This contrasts with Smith’s argument that the lower court relied on a comprehensive body of evidence beyond a singular IQ score. Alabama sought to make a case at the Supreme Court level to establish a standardized method for evaluating multiple IQ scores.
The recent Supreme Court decision not to engage leaves Justice Sonia Sotomayor’s concurring opinion standing, which outlines that there is no explicit constitutional formula for weighing multiple IQ scores. She highlighted that neither state legislatures nor courts have created a standard requiring the cumulative consideration of IQ scores, just as no explicit prohibition exists against the method used by the District Court.
In dissent, Justice Clarence Thomas criticized the precedent set by Atkins, arguing that the Eighth Amendment does not encompass claims like Smith’s. Justice Samuel Alito, supported partially by Chief Justice John Roberts and Justice Neil Gorsuch, suggested multiple methodologies for determining an IQ score in such cases, encouraging a standardized approach.
The dismissal of this case implies continued ambiguity for similar future cases, as the legal community must navigate this complex issue without broader guidance on how to integrate multiple IQ score assessments in determining intellectual disabilities in capital cases. For further details on the case proceedings and Court opinions, refer to the full coverage of the story.