The U. S.
Supreme Court dismissed a capital punishment case from Alabama on Thursday in a narrow 5-4 decision.
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The ruling leaves intact a lower court decision that spared death row inmate Joseph Clifton Smith from execution due to intellectual disability.
The high court issued an unsigned order stating that the writ of certiorari was dismissed as improvidently granted.
This means the justices determined they should not have taken the case after hearing oral arguments.
The legal dispute centered on how courts evaluate multiple intelligence quotient scores to determine intellectual disability. Such a status outlaws execution under the Eighth Amendment.
Smith was convicted of first-degree murder for the 1997 killing of Durk Van Dam during a robbery. He later challenged his death sentence based on his intellectual functioning.
Court records show Smith took five IQ tests over nearly 40 years, scoring 75 in 1979, 74 in 1982, 72 in 1998, 78 in 2014, and 74 in 2017.
Alabama officials argued that a score of 70 or less was required to prove disability.
Justices Divided on Approach
Justice Sonia Sotomayor authored a concurring opinion alongside Justice Ketanji Brown Jackson.
She explained that the evidentiary record was insufficient to establish a nationwide formula for weighing fluctuating test scores.
"The court is not equipped in this case to provide any meaningful guidance on how courts should assess multiple IQ scores," Sotomayor wrote.
She noted that all parties agreed the Constitution does not mandate a singular mathematical formula.
Sotomayor suggested that clinical standards should continue to guide lower courts on a case-by-case basis.
She concluded that the high court acted correctly by stepping away from the litigation under the current circumstances.
Justice Samuel Alito led the dissent, joined by Chief Justice John Roberts, Justice Clarence Thomas, and Justice Neil Gorsuch.
Alito argued the court failed its duty to clarify capital jurisprudence.
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"The court shies away from its obligation to provide workable rules for capital cases," Alito wrote.
He stated that the dismissal leaves local jurisdictions and lower courts without necessary legal guideposts.
Alito warned that continuous silence from the high court would invite future legal challenges seeking to undo established constitutional protections for disabled individuals.
Justice Clarence Thomas issued a separate solo dissent.
He argued that the landmark 2002 precedent protecting intellectually disabled individuals from the death penalty lacks historical constitutional backing.
"To avoid execution, Smith tried to convince courts that he is not intelligent enough to be executed. Today, the Court rewards Smith’s efforts," Thomas wrote.
He explicitly called for the court to reconsider and overturn its foundational ruling on the matter.
Advocates Praise Decision
Disability advocacy groups praised the procedural dismissal.
They stated it preserves a holistic clinical framework that looks beyond raw numbers to evaluate social and adaptive skills.
"A Supreme Court decision could have potentially narrowed protections for people with intellectual disabilities against being executed," said Jennifer Mathis, Deputy Director at the Bazelon Center for Mental Health Law.
She noted that a restrictive ruling could have negatively impacted disability service eligibility outside the criminal justice system.
Legal advocates emphasized that Alabama’s request would have disregarded established medical science by focusing exclusively on standardized testing thresholds.
"It is settled law that executing people with intellectual disability is unconstitutional," said Shira Wakschlag, Senior Executive Officer for Legal Advocacy and General Counsel at The Arc.
She added that comprehensive evaluations remain necessary to protect vulnerable individuals from unlawful execution.
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According to data from the Death Penalty Information Center, up to 20 percent of the approximately 2,100 people currently on death row in the United States may have an intellectual disability.
