By John Kruzel
WASHINGTON (Reuters) -The U.S. Supreme Court agreed on Friday to hear an appeal by Alabama officials of a judicial decision that a man convicted of a 1997 murder is intellectually disabled – a finding that spared him from the death penalty – as they press ahead with the Republican-governed state’s bid to execute him.
A lower court ruled that Joseph Clifton Smith is intellectually disabled based on its analysis of his IQ test scores and expert testimony. Under a 2002 Supreme Court precedent, executing an intellectually disabled person violates the U.S. Constitution’s Eighth Amendment bar on cruel and unusual punishment.
The justices are due to hear the case in their next term, which starts in October.
Smith, now 54, was convicted and sentenced to death for the 1997 murder of a man named Durk Van Dam in Alabama’s Mobile County. Smith fatally beat the man with a hammer and saw in order to steal his boots, some tools and $140, according to evidence in the case. The victim’s body was found in his mud-bound Ford Ranger truck in an isolated, wooded area.
The Supreme Court’s 2002 precedent in a case called Atkins v. Virginia barred executing intellectually disabled people.
President Donald Trump’s administration backed Alabama’s appeal in the case.
The issue that the court will consider in Smith’s case is whether and how courts may consider the cumulative effect of multiple intelligence quotient (IQ) scores in assessing a death row inmate’s intellectual disability.
Like many states, conservative-leaning Alabama considers evidence of IQ test scores of 70 or below as part of the standard for determining intellectual disability. Supreme Court rulings in 2014 and 2017 allowed courts to consider IQ score ranges that are close to 70 along with other evidence of intellectual disability, such as testimony of “adaptive deficits.”
Smith had five IQ test scores, the lowest of which was 72. A federal judge noted that Smith’s score could be as low as 69, given the standard of error of plus or minus three points. The judge then found that Smith had significant deficits from an early age in social and interpersonal skills, independent living and academics.
The Atlanta-based 11th U.S. Circuit Court of Appeals upheld the judge’s conclusions in 2023, setting aside Smith’s death sentence. This prompted Alabama officials to file their first of two appeals to the Supreme Court in the case.
In November, the justices threw out the 11th Circuit’s decision, saying that the lower court’s evaluation of Smith’s IQ scores can be read two ways, and requires clarification.
Ten days later, the 11th Circuit issued an opinion clarifying that its evaluation was based on “a holistic approach to multiple IQ scores” that also considered additional relevant evidence, including expert testimony. This prompted a second appeal by Alabama officials to the Supreme Court.
Alabama in its filing to the Supreme Court argued that the lower courts in the case applied the wrong legal standard in establishing Smith’s intellectual disability and urged the justices to take up the appeal to provide clarity on the issue.
(Reporting by John Kruzel; Editing by Lisa Shumaker)
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