US Supreme Court Leaves Intact Ruling Protecting Death Row Inmate with Intellectual Disability from Execution

In the case of Hamm v. Smith, No. 24-872, the Supreme Court of the United States issued a per curiam opinion dismissing the writ of certiorari as improvidently granted. This critical decision left intact an Eleventh Circuit ruling that was highly favorable to death-row petitioner Joseph Clifton Smith. Smith’s federal habeas relief turned on whether his cognitive limitations met Alabama's legal definition of intellectual disability, which constitutionally bars execution under the Eighth Amendment.  

While the State of Alabama argued that Smith’s five IQ scores ranging from 72 to 78 placed him in a borderline range just above the traditional 70 cutoff, Smith’s experts successfully countered that these metrics cannot be viewed in isolation. Accounting for the standard margin of error, his actual capabilities could fall below 70, requiring courts to evaluate testing data alongside his severe, documented adaptive functioning deficits.  

Ultimately, the Supreme Court's dismissal represents an implicit endorsement of a holistic framework for intellectual disability evaluations. It confirms that courts must look far beyond rigid numerical thresholds. Capital assessments require a thorough exploration of real-world adaptive executive functioning, analyzing critical everyday life skills like communication, social processing, and functional academics, rather than relying solely on an inflexible metric to determine his death penalty execution eligibility.