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In an unusual step on Thursday, the Supreme Court saved the life of an inmate on death row deemed to be "intellectually disabled," turning down an appeal from Alabama authorities who contended that the man’s various IQ results indicated he is competent and eligible for the death penalty.
The justices were closely divided, 5-4, in permitting a prior court’s judgment to remain, which stated that putting Joseph Clifton Smith, a convicted murderer in the first degree, to death would be a breach of the Eighth Amendment’s bar against "cruel and unusual" punishment.
The high court did not offer a formal rationale for its ruling.
Over two decades ago, the high court prohibited the execution of individuals with intellectual disabilities who were convicted of capital offenses.
The core of the Smith situation involved a disagreement over the criteria for intellectual disability and the method for interpreting contradictory intelligence quotient – also known as IQ – assessment scores when making this determination.
Joseph Clifton Smith is shown in this booking photo released by the Alabama Department of Corrections.Alabama Department of Corrections
The ruling on Thursday left that matter unresolved.
“The court lacks the capacity in this instance to present substantial guidance on how courts should evaluate various IQ results,” wrote Justice Sonia Sotomayor in a concurring opinion, which Justice Ketanji Brown Jackson joined.
Despite state officials having requested the court to establish a definitive criterion, Sotomayor proposed that a case-specific methodology, taking into account legal precedent and “the perspectives of medical professionals,” ought to be maintained.
“Should a conflict emerge among the states or lower courts, and a case properly presents the issue, it may be fitting for this court to offer input with more detailed guidance,” she stated. “The court correctly determines that it is not suitable to do so in this case.”
Justices Clarence Thomas, Samuel Alito, Neil Gorsuch, and Chief Justice John Roberts dissented.
"The court avoids its responsibility to furnish practical regulations for capital cases," Justice Alito stated in a dissent, which Thomas, Gorsuch, and Roberts joined. "In acting this way, the court neglects its own jurisprudence on the death penalty, the criminal justice systems of states, lower courts, and the victims of terrible homicides."
Justice Thomas wrote separately to argue for the reinstitution of the death penalty for individuals with intellectual disabilities.
Smith, who will now serve a life sentence, admitted to a murder committed during a 1997 robbery but challenged his death sentence on the basis that he has had "markedly below average intellectual functioning" since childhood.
He has undergone five distinct IQ tests over roughly 40 years, achieving scores of 75 in 1979, 74 in 1982, 72 in 1998, 78 in 2014, and 74 in 2017.
Individuals with scores below 70 are generally regarded as having an intellectual disability, but prominent American medical organizations advocate for a thorough assessment that also evaluates social and practical capabilities.
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The groups emphasize that standardized test scores alone should not be definitive. Smith’s score of 72, for instance, could potentially be 69 when considering the 3-point margin for error.
Smith, who claims to have experienced physical and verbal mistreatment during his childhood, consistently performed at levels two grades below his grade placement in school, as per court documents. Smith’s school categorized him as "Educable Mentally Retarded" in the 7th grade before he eventually withdrew.
Two lower federal tribunals concluded that a comprehensive examination of Smith’s IQ scores and supplementary proof, encompassing his behavioral background and academic records, demonstrated that he has an intellectual disability.
"Joseph Smith does not have an intellectual disability, and the Eighth Amendment does not nullify the death sentence he earned for the murder of Durk Van Dam," Alabama asserted in its submission to the court. "The methodology for weighing multiple IQ scores is a matter left to the discretion of the state."
The state contended that an intellectual disability can only be verified by an IQ score of 70 or less by a preponderance of the evidence.
By one calculation, possibly as many as 20% of the 2,100 individuals on death row in the U.S. may possess some degree of intellectual disability, according to the Death Penalty Information Center.
Sourse: abcnews.go.com