United States: The U.S. Supreme Court nullified a judicial decision on Monday that had helped a man convicted of murder in Alabama escape execution, this due to intellectual disability.
Background of the Case
The justices agreed that the Atlanta-based 11th U.S. Circuit Court of Appeals needs to elaborate its decision that Joseph Clifton Smith, who has been sentenced to death for a 1997 murder, has to have his death sentence overturned because executing mentally challenged individual is ‘cruel and unusual punishment’ which is in violation of the 8th Amendment to U.S Constitution, as reported by Reuters.
Smith was arrested and later sentenced to death for the 1997 murder of Durk Van Dam in Mobile County, Alabama. Smith struck the man with a hammer and saw, which led to his death with a view of robbing him of his boots, some tools, and $140. He was found dead inside his vehicle, a mud-stuck Ford Ranger truck in a deserted forested region.
Intellectual Disability Standards
This holds the Supreme Court’s previous decision made in 2002 regarding Atkins v. Virginia, which held that the execution of people with intellectual disability was a violation of their constitutional rights.
The US Supreme Court has thrown out a judicial decision that has spared a man convicted of murder in Alabama from execution because he was found to be intellectually disabledhttps://t.co/wozC3Ru56a
— RTÉ News (@rtenews) November 4, 2024
As in other conservative states, for a person to be qualified as an intellectually disabled in Alabama, there has to be evidence of an IQ score of 70 or below. The Supreme Court’s two decisions in 2014 and 2017 enabled the courts to look at various IQ ranges that are proximate to 70, along with other contentions for intellectual disability or mental fitness like the opinion of “adaptive deficits.”
Smith’s IQ Evaluation
Smith once took five IQ tests, and the minimum score was 72. A federal judge pointed out that Smith’s score could be as low as 69 because of the margin of ±3 points. The judge then determined that since Smith’s early childhood, he demonstrated serious deficits in social /interpersonal and academic domains as well as self-sufficient living skills.
Alabama’s Appeal and Supreme Court Review
The ruling of the 11th Circuit affirming the judge’s judgment was in 2023, and thus, the death penalty on Smith was reduced.
“Smith is not intellectually disabled,” Alabama argued to the Supreme Court, stating that the 11th Circuit “twisted law and logic,” arguing that based on Smith’s lowest tested IQ, he was indeed intellectually disabled.
Scotus threw out a judicial decision that had spared a man convicted of murder in Alabama from execution because he was found to be intellectually disabled https://t.co/94lJHmJJxk pic.twitter.com/uWPxnXv38D
— Reuters Legal (@ReutersLegal) November 4, 2024
The justices declared in a brief and un/menued order on Monday that the 11th Circuit’s approach to Smith’s IQ scores can be seen in two ways and that it needs further definition. This is because the Supreme Court’s consideration of the state’s appeal in the case “may depend on the basis” of the 11th Circuit’s decision, the opinion states.
Justice Opinions
Senior Justice Clarence Thomas and Justice Neil Gorsuch concurred with the dissenting opinion. They would have granted the petition for writ of certiorari and put to a hearing Alabama’s appeal, as reported by Reuters.
On average, the Supreme Court takes weeks, sometimes days, to decide whether or not to hear any appeal, and this one took months – Alabama filed the appeal in August 2023.