By John Kruzel
WASHINGTON, May 21 (Reuters) – The U.S. Supreme Court on Thursday dismissed a challenge by Alabama officials to a judicial finding that a death row inmate convicted of a 1997 murder is intellectually disabled and thus ineligible for the death penalty.
The justices said that the case had been “improvidently granted” by the court, effectively undoing its earlier decision to take up the matter. The court heard arguments in the dispute in December.
The court had taken up an appeal by Alabama officials to the lower court’s approach to determining Joseph Clifton Smith’s intellectual capacity, a method that had weighed multiple intelligence quotient, or IQ, test scores alongside expert testimony.
Under a 2002 Supreme Court precedent, executing an intellectually disabled person violates the U.S. Constitution’s Eighth Amendment ban on cruel and unusual punishment. At issue in Smith’s case was whether and how courts may consider the cumulative effect of multiple IQ scores in assessing a death row inmate’s intellectual disability.
Republican President Donald Trump’s administration backed the state of Alabama in the case.
Liberal Justices Sonia Sotomayor and Ketanji Brown Jackson concurred in the Supreme Court’s decision to dismiss the case. Conservative Justices Clarence Thomas and Samuel Alito dissented. Chief Justice John Roberts and fellow conservative Justice Neil Gorsuch joined Alito’s dissent in part.
Smith, now 55, 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, 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.
Like many states, 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, ranging from a high of 78 to a low of 72. A federal judge noted that Smith’s lowest score could in fact be as low as 69, given the standard error of measurement, or SEM, of roughly plus or minus three IQ 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 the first of two appeals to the Supreme Court in the case.
The justices in 2024 threw out the 11th Circuit’s decision, saying that the lower court’s evaluation of Smith’s IQ scores could be read two ways, and required clarification.
The 11th Circuit responded with 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 the second appeal by Alabama officials to the Supreme Court.
(Reporting by John Kruzel; Editing by Will Dunham)
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