Moore v. Texas, 137 S. Ct. 1039

Background

Bobby James Moore, tried for a 1980 capital murder committed at age 20, was resentenced to death and later sought habeas relief claiming intellectual disability under Atkins.
A state habeas court applied contemporary clinical manuals (AAIDD–11 and DSM‑5), found IQ and adaptive deficits (average of credited IQ scores ≈ 70.66 and adaptive deficits in conceptual, social, practical domains), and recommended relief.
The Texas Court of Criminal Appeals (CCA) refused relief, relying on its precedent Ex parte Briseno (adopting AAMR‑9 standards), credited only two higher IQ scores (78 and 74), discounted the lower SEM range, and applied seven nonclinical “Briseno factors” including a relatedness requirement.
The Supreme Court granted certiorari to review whether the CCA’s approach comported with the Eighth Amendment and this Court’s decisions in Atkins and Hall.
The Court vacated the CCA decision, holding that courts must be informed by current medical diagnostic standards; the CCA erred in (1) improperly treating Moore’s IQ evidence, (2) overemphasizing adaptive ‘‘strengths’’ and prison behavior, (3) misusing trauma and co‑occurring conditions to rebut relatedness, and (4) relying on Briseno’s lay factors.

Issues

Issue	Plaintiff's Argument (Moore)	Defendant's Argument (Texas/CCA)	Held
1. Must courts apply/heed current medical diagnostic standards in Atkins claims?	Courts should use current AAIDD/DSM guidance to evaluate intellectual disability.	States have discretion to adopt procedures; CCA may rely on its Briseno standard.	Yes — Atkins/Hall require that States’ procedures be informed by the medical community; CCA erred by clinging to Briseno and superseded standards.
2. How to treat IQ scores close to 70 and the standard error of measurement (SEM)?	IQs near 70 must be adjusted for SEM and the lower bound considered; then assess adaptive functioning.	CCA relied on select scores and discounted the lower SEM bound due to situational factors.	SEM must be accounted for; because Moore’s adjusted range included ≤70, the court had to proceed to adaptive‑functioning inquiry. CCA’s rejection of the SEM lower bound was inconsistent with Hall.
3. What is the proper focus in assessing adaptive functioning (deficits vs. strengths; prison behavior)?	Focus on adaptive deficits per clinical standards; avoid overweighting skills gained in controlled/prison settings.	CCA emphasized adaptive strengths (work, survival, trial comportment, prison improvement) and used them to downplay deficits.	Court held the medical community focuses on deficits; CCA overemphasized strengths and improperly relied on prison behavior.
4. May courts apply Briseno’s seven nonclinical factors and require ‘‘relatedness’’ to exclude disability?	Briseno factors are lay‑based, not medically grounded, and risk excluding people who meet clinical criteria.	Briseno implements an objective Texas standard and helps determine relatedness; CCA retained it as precedent.	No — Briseno’s lay factors and relatedness application depart from clinical standards, create unacceptable risk, and may not restrict Atkins claims.

Key Cases Cited

Atkins v. Virginia, 536 U.S. 304 (2002) (Eighth Amendment bars execution of intellectually disabled persons)
Hall v. Florida, 572 U.S. (2014) (States must account for IQ test SEM and be informed by medical diagnostic framework)
Roper v. Simmons, 543 U.S. 551 (2005) (Evolving standards of decency and protection of human dignity inform Eighth Amendment analysis)