The United States Supreme Court has dismissed a judicial ruling that had saved a man convicted of murder in Alabama from execution due to a finding of intellectual disability.
The justices determined that the Atlanta-based 11th U.S. Circuit Court of Appeals must clarify its decision that Joseph Clifton Smith’s death sentence for a 1997 murder should be overturned based on the Supreme Court’s 2002 ruling prohibiting the execution of intellectually disabled individuals as cruel and unusual punishment under the Eighth Amendment of the U.S. Constitution.
Smith was found guilty and sentenced to death for the murder of Durk Van Dam in Mobile County, Alabama, in 1997. Evidence revealed that Smith brutally bludgeoned Van Dam with a hammer and saw to steal his boots, tools, and $140.
The victim’s remains were discovered in his mud-drenched Ford Ranger truck in a remote, wooded area.
IQ test scores
Similar to many states, conservative Alabama incorporates IQ test scores of 70 or below as part of its criteria for establishing intellectual disability.
Supreme Court decisions in 2014 and 2017 permitted courts to evaluate IQ scores that are near 70 in conjunction with additional evidence of intellectual disability, including testimony regarding “adaptive deficits”.
Smith’s IQ test results included five scores, with the lowest being 72.
A federal judge indicated that Smith’s score might be as low as 69, considering the standard error margin of plus or minus three points.
The judge also observed that Smith exhibited significant deficits from a young age in social skills, interpersonal interactions, independent living, and academics.
The 11th Circuit upheld the judge’s findings in 2023, thus nullifying Smith’s death sentence.
‘Smith not intellectually disabled’ – appeal
“Smith is not intellectually disabled,” Alabama asserted in its appeal to the Supreme Court, arguing that the 11th Circuit had “twisted law and logic” by focusing excessively on Smith’s lowest IQ score to conclude he was intellectually disabled.
The justices, in a brief unsigned opinion today, stated that the 11th Circuit’s assessment of Smith’s IQ scores could have two interpretations and necessitates clarification.
The Supreme Court’s review of the state’s appeal regarding this case “may hinge on the reasoning” behind the 11th Circuit’s decision, as per the opinion.
Conservative Justices Clarence Thomas and Neil Gorsuch expressed that they would have preferred to hear and schedule arguments for Alabama’s appeal.
The Supreme Court deliberated for an exceptionally long period on whether to entertain Alabama’s appeal, which was submitted in August 2023.
