604 U.S. 1
SCOTUS2024Background
- Joseph Clifton Smith was sentenced to death for the murder of Durk Van Dam in Alabama.
- The U.S. District Court vacated Smith’s death sentence, finding he is intellectually disabled, partly based on IQ scores ranging from 72 to 78.
- Intellectual disability was central—if Smith's IQ was 70 or below, he would be ineligible for execution per Supreme Court precedent.
- The District Court considered the standard error of measurement, finding Smith’s IQ could be as low as 69.
- The Eleventh Circuit affirmed the District Court’s decision, but its rationale was unclear whether it focused solely on the lowest score’s statistical range or took a holistic view of all scores.
- The Supreme Court granted certiorari, vacated, and remanded for further clarification by the Eleventh Circuit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| How to assess multiple IQ scores for ID | Smith argued the lowest possible IQ, accounting for measurement error, shows disability. | Hamm argued a holistic view of all scores is necessary, not just the lowest. | Remanded for clarification—unclear which approach Eleventh Circuit used. |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (2002) (finding execution of intellectually disabled persons unconstitutional)
- Hall v. Florida, 572 U.S. 701 (2014) (requiring courts to consider standard error in IQ scores for death penalty eligibility)
- Moore v. Texas, 581 U.S. 1 (2017) (requiring courts to use contemporary medical standards for assessing intellectual disability)
- Brumfield v. Cain, 576 U.S. 305 (2015) (discussing procedure for determining intellectual disability in capital cases)