The question
Whether the Eleventh Circuit applied a per se rule treating the lower end of the standard-error range for an offender's lowest IQ score as dispositive of intellectual disability, or instead a holistic approach weighing all relevant evidence.
Hamm v. Smith
What the Court decided
The Court vacated the Eleventh Circuit's judgment and remanded the case. The Eleventh Circuit had affirmed the vacatur of Joseph Clifton Smith's death sentence on a finding that he is intellectually disabled. The Court found the Eleventh Circuit's opinion unclear as to whether it applied a per se rule making the lower end of the standard-error range for the lowest IQ score dispositive, or a holistic approach considering all relevant evidence including expert testimony. The Court remanded for the Eleventh Circuit to clarify the basis for its decision.
How the justices split
7-2Per curiam (unsigned)
Delivered by the Court
The Court held that the Eleventh Circuit's opinion could be read two ways: as applying a per se rule that the lower end of the standard-error range for the lowest IQ score is dispositive, or as applying a holistic approach that weighs all relevant evidence including expert testimony. Because the opinion was unclear and the Court's assessment of any future certiorari petition may depend on the basis for the decision, the Court vacated the judgment and remanded for the Eleventh Circuit to clarify the basis for its decision.
Dissenting
Thomas, joined by Gorsuch
Justice Thomas and Justice Gorsuch would grant the petition for a writ of certiorari and set the case for argument rather than vacate and remand.
How we know · 5 sourced claims
The judgment of the Eleventh Circuit was vacated and the case remanded for the Eleventh Circuit to clarify the basis for its decision.
Source: syllabus, Held
The District Court vacated Joseph Clifton Smith's death sentence after concluding he is intellectually disabled.
Source: syllabus, Held
Smith obtained five full-scale IQ scores ranging from 72 to 78, and his claim depended in part on whether his IQ is 70 or below.
Source: syllabus, Held
The Eleventh Circuit's opinion could be read either as a per se rule treating the lower end of the standard-error range for the lowest score as dispositive, or as a more holistic approach considering all relevant evidence.
Source: syllabus, Held
Justice Thomas and Justice Gorsuch would grant the petition for a writ of certiorari and set the case for argument.
Source: syllabus, lineup