The Supreme Court is set to review the implications of IQ tests in death penalty cases concerning individuals with intellectual disabilities. This decision follows the 2002 ruling in Atkins v. Virginia, which prohibits the execution of intellectually disabled persons. The upcoming case, Hamm v. Smith, will scrutinize how courts should assess a defendant’s claims regarding intellectual disability based on multiple IQ tests.
Background on Hamm v. Smith
On December 10, the Supreme Court will hear arguments regarding Joseph Smith, who was convicted of murder and sentenced to death for the 1997 robbery and killing of Durk Van Dam. The lower courts had differing views on Smith’s IQ, which ranged from 72 to 78 across five tests. This range raises significant questions about whether Smith meets the criteria for intellectual disability, which Alabama law defines as having an IQ of 70 or below.
Contentions from Both Parties
- The state of Alabama argues that the lower court overly focused on isolated IQ test results. They claim the cumulative IQ scores indicate Smith is not intellectually disabled.
- Smith counters that the lower court considered a broad range of evidence beyond just IQ scores, including expert testimonies.
Journey Through the Legal System
After Smith’s initial appeals were dismissed in state courts, he sought relief in federal court. Senior U.S. District Judge Callie V.S. Granade ruled in Smith’s favor, stating he showed significant intellectual deficits. The 11th Circuit Court upheld this ruling in May 2023.
The case’s complex path led the Supreme Court to reconsider it several times, ultimately directing the 11th Circuit to clarify its earlier ruling in November 2024.
State’s Arguments and Judicial Perspectives
Alabama’s stance emphasizes that there is no national consensus on treating multiple IQ scores in legal contexts. They cite variations in how states interpret these scores, some focusing on the lowest and others on the highest. They claim that Smith’s highest score, which is above the threshold, negates his argument for intellectual disability.
Smith, however, argues for a holistic assessment of multiple IQ scores, which should incorporate additional evidence like behavioral history and other cognitive evaluations.
The Role of Expert Testimonies
The debate centers on how to interpret IQ scores and the significance of expert testimony in establishing intellectual disability. Smith’s legal team highlights the long-standing medical standards used for diagnosing intellectual disabilities, which the state contests as evolving.
Implications of the Supreme Court’s Decision
The forthcoming ruling could redefine how courts assess intellectual disability in capital cases, particularly in the context of executing individuals with varying IQ scores. As debates persist about the ethical implications of such executions, the Supreme Court’s decision will have profound effects on future cases involving the death penalty.
