Supreme Court to Address Evaluation of Multiple Intelligence Tests in Death Penalty Cases
The Supreme Court is set to address the issue of evaluating multiple intelligence tests for inmates who are intellectually disabled and facing execution. The case involves Alabama death row inmate Joseph Smith, who was convicted of a brutal murder in 1997. Smith's IQ scores have varied between 72 and 78, leading to uncertainty about his intellectual disability status. The state argues that with five test scores above 70, Smith's IQ is likely not below 70, a key factor in defining intellectual disability.
The Justice Department has raised concerns about the confusion among lower courts in evaluating multiple IQ tests under the Eighth Amendment's prohibition of cruel and unusual punishment. Smith's lawyers argue that there is no exact formula for determining intellectual disability, as previously stated by the Supreme Court. The high court previously ordered the 11th U.S. Circuit Court of Appeals to clarify its decision on Smith's case, questioning the approach taken in evaluating his disability.
In addition to IQ scores, other factors such as deficits in adaptive behavior and the onset of these qualities before age 18 are considered in defining intellectual disability. The appeals court emphasized that clinicians look beyond IQ tests to diagnose significantly subaverage intellectual functioning. The court highlighted that multiple IQ tests with similar results may not be sufficient due to potential flaws in the test itself or improper administration.
Smith's case involves the 1997 murder of Durk Van Dam, where the victim sustained multiple blunt force injuries and wounds. U.S. District Judge Callie V. S. Granade described the evaluation of Smith's mental functioning as a "close case," noting evidence of lifelong deficiencies in intelligence and adaptive functioning. The Supreme Court's decision on how to assess multiple intelligence tests in cases of intellectual disability will have significant implications for the implementation of capital punishment.