Supreme Court Dismissal Keeps Intellectually Disabled Man Off Death Row
A man's life was spared on May 21 when the U.S. Supreme Court dismissed a case that has implications for how disabled people will be treated within the American criminal justice system. Here is a closer look at the case dismissal, as well as what legal precedent it sets going forward.
Supreme Court Spares Alabama Man's Life on Grounds of His Intellectual Disability
The Supreme Court declined to revisit the historic standard guiding when an intellectual disability should stand in the way of a death penalty ruling. The brief, unsigned opinion released on Thursday notes that the court should not have taken on the case surrounding whether Alabama should be able to execute a convicted murderer with an intellectual disability.
The dismissal by the highest court in the land means that the lower court's ruling will remain in place. The lower court had ruled that Joseph Smith had a significant enough cognitive disability to make him ineligible to be on death row. The 55-year-old had been convicted of beating a man to death in 1997.
Justice Samuel Alito penned the dissent, writing that the court ignored its duty to provide what he called "workable rules for capital cases." Alito was joined in the dissent by Chief Justice John Roberts, Justice Neil Gorsuch, and Clarence Thomas.
Thomas also weighed in, saying that he believed that the court should overrule the 2002 case Atkins v. Virginia that banned the execution of people with confirmed intellectual disability. The staunch conservative justice wrote that the 2002 decision "has bred only confusion and absurdity."
Justice Sonia Sotomayor joined the majority decision not to hear the execution standards, noting that the other methods of assessing cognitive capabilities had not been tested before the case made its way up to the highest court. Sotomayor wrote, “Without the benefit of an evidentiary record or decisions below trained on the specific theories now advanced by the parties, this Court rightly concludes that it should not provide more detailed guidance beyond what this Court’s cases have previously said.”
Why the Dismissal is So Important
Disability rights groups had been deeply invested in this case, largely due to the potential implications that go well beyond the court system. Americans with an official diagnosis of intellectual disability may qualify for a variety of government support programs. These services include everything from special education to free or subsidized health care.
Advocacy groups were concerned that the court's ruling could move the needle more toward IQ tests used for formal diagnoses without factoring in other pertinent data. According to these advocacy groups, death penalty cases represent just a small fraction of intellectual disability assessments. However, justices are often compelled to hear testimony that does not align with whether an inmate on death row has a disability severe enough to prevent execution. Those with intellectual disabilities are protected under the Eighth Amendment ban on cruel and unusual punishments.
Smith has been on death row for over 20 years. He has been formally tested a total of five times, with IQ scores ranging from 72 to 78. A score of below 70 is considered to be the threshold for an intellectual disability. Smith's attorneys had argued that his IQ could be at or below 70 due to the error range. Conversely, the state of Alabama argued that since all five scores came in above 70, Smith cannot prove that he is disabled.
The Trump administration was in support of Alabama's right to carry through with Smith's execution. The U.S. Department of Justice (DOJ) argued that individual states have the authority to define what it means to be intellectually disabled. The DOJ also said that the states should have leeway to determine what a defendant needs to do to prove they are indeed disabled.
In the Hamm v. Smith case, Smith's lawyers argued that the IQ scores must be looked at holistically. This means determining the level of disability in conjunction with testimony from experts about the test's validity. Smith's legal team also contended that defendants should be allowed to present additional evidence if the IQ scores are inconclusive.
Smith was diagnosed as being "educable mentally retarded" in seventh grade. This was the term used to define individuals with mild intellectual disabilities at the time of their diagnosis. His lawyers also noted that he was physically abused as a child, struggling in school, and with emotional issues.
Smith had a criminal history prior to the murder. He beat Durk Van Dam to death shortly after being released from prison on a burglary conviction. According to court records, Smith also stole Van Dam’s boots, tools, and a total of $140 in cash.
U.S. District Judge Callie V. S. Granade originally ruled that Smith's mental capabilities were a "close case." However, she said that the evidence suggested Smith has been "deficient throughout his life" when it came to cognitive function. The Atlanta-based 11th U.S. Circuit Court of Appeals upheld this ruling.
According to the Death Penalty Information Center, there have been 144 people who have had their death sentences reversed because of intellectual disabilities since a 2002 Supreme Court ruling.
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