By John Kruzel
WASHINGTON, May 21 (Reuters) – A man convicted of a 1997 murder in Alabama will be spared execution after the U.S. Supreme Court on Thursday kept in place a judicial finding that the inmate is intellectually disabled and thus ineligible for the death penalty.
The justices dismissed an appeal by Alabama officials of a lower court’s approach to determining Joseph Clifton Smith’s intellectual capacity. That method involved weighing multiple intelligence quotient, or IQ, test scores alongside expert testimony.
Under a 2002 Supreme Court precedent in a case called Atkins v. Virginia, executing an intellectually disabled person violates the U.S. Constitution’s Eighth Amendment ban on cruel and unusual punishment.
At issue in Smith’s case was whether and how courts may consider the cumulative effect of multiple IQ scores in assessing a death-row inmate’s intellectual disability.
Kacey Keeton, a lawyer for Smith, said he will be resentenced by state courts and moved from death row.
“Joseph Smith has spent decades on death row while courts examined whether the Constitution protects him. Today, it does,” Keeton said, adding that the court’s decision had brought her client and his family “profound relief.”
“The District Court listened carefully to experts on all sides and concluded that Mr. Smith is intellectually disabled,” Keeton added. “The Supreme Court declined to disturb that finding, and Mr. Smith will not be executed.”
Republican President Donald Trump’s administration had backed Alabama in the case.
Smith, now 55, was convicted and sentenced to death for the 1997 murder of a man named Durk Van Dam in Alabama’s Mobile County. Smith fatally beat the man with a hammer and saw in order to steal his boots, tools and $140, according to evidence in the case. The victim’s body was found in his mud-bound Ford Ranger truck in an isolated, wooded area.
The Supreme Court heard arguments in the dispute in December, but said on Thursday that it should not have taken up Alabama’s appeal.
Liberal Justices Sonia Sotomayor and Ketanji Brown Jackson concurred in the decision to dismiss the case. Conservative Justices Clarence Thomas and Samuel Alito dissented. Chief Justice John Roberts and fellow conservative Justice Neil Gorsuch joined Alito’s dissent in part.
“Nothing in our case law sanctioned the lower courts’ analyses, and we should have used this case to bring clarity to our Atkins doctrine,” Alito wrote.
“By instead remaining silent,” Alito wrote, “the court exacerbates the confusion that plagues our jurisprudence in this area.”
Like many states, Alabama considers evidence of IQ test scores of 70 or below as part of the standard for determining intellectual disability. Supreme Court rulings in 2014 and 2017 allowed courts to consider IQ score ranges that are close to 70 along with other evidence of intellectual disability, such as testimony of “adaptive deficits.”
Smith had five IQ test scores, ranging from a high of 78 to a low of 72. A federal judge noted that Smith’s lowest score could in fact be as low as 69, given the standard error of measurement of roughly plus or minus three IQ points. The judge then found that Smith had significant deficits from an early age in social and interpersonal skills, independent living and academics.
The Atlanta-based 11th U.S. Circuit Court of Appeals upheld the judge’s conclusions in 2023, setting aside Smith’s death sentence. This prompted Alabama officials to file the first of two appeals to the Supreme Court in the case.
The Supreme Court in 2024 threw out the 11th Circuit’s decision, saying that the lower court’s evaluation of Smith’s IQ scores could be read two ways, and required clarification.
The 11th Circuit responded with an opinion clarifying that its evaluation was based on “a holistic approach to multiple IQ scores” that also considered additional relevant evidence, including expert testimony. This prompted the second appeal by Alabama officials to the Supreme Court.
(Reporting by John Kruzel; Editing by Will Dunham)
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