Supreme Court Dismisses Death Penalty IQ Case Without New Guidance

The Supreme Court dismissed the death penalty case Hamm v. Smith on Thursday without issuing new rules for how courts should evaluate multiple IQ scores. A majority of justices concluded that the case did not provide an adequate record for setting a precise methodology. The decision leaves lower courts to continue applying existing precedents when defendants raise intellectual disability claims.

Smith was sentenced to death in Alabama and argued he is intellectually disabled. He cited IQ scores ranging from 72 to 78, with standard error margins that could place him below 70. Lower courts determined that Smith is intellectually disabled. Alabama asked the Supreme Court to clarify how courts should handle multiple IQ scores in such cases.

Alito wrote that the court should have used the case to bring clarity to its doctrine on intellectual disability and the death penalty. He stated the ruling exacerbates existing confusion in this area of law. Justice Clarence Thomas also filed a dissenting opinion. Alito further wrote that the court's earlier Atkins decision has produced confusion and that nothing in the Constitution supports it.