Hamm v. Smith

Background

A man on death row was convicted of murder and sentenced to death. The state corrections agency pursued his execution, but a federal trial judge concluded he is intellectually disabled and vacated the death sentence. The judge relied in part on five full-scale IQ scores ranging from 72 to 78 and noted that the lowest score’s standard-error range could reach 69.

Reasoning

The core question was how courts should evaluate multiple IQ test scores when deciding whether someone is intellectually disabled. The Court explained that earlier rulings require assessing each score and considering measurement error, but the Court has not said exactly how to weigh several scores together. The Eleventh Circuit’s opinion was unclear—it could be read as treating the lower bound of the lowest score as automatically decisive or as endorsing a holistic review of all scores and evidence. Because the appeals court’s reasoning was ambiguous, the Court granted review, vacated the Eleventh Circuit’s judgment, and sent the case back for a clearer, evidence-focused reconsideration.

Real world impact

The decision directs lower courts to be clearer about how they handle multiple IQ results in death-penalty disability claims. People with borderline IQ scores, defense teams, and prosecutors may see different outcomes depending on how courts weigh scores and expert evidence. This ruling is not a final decision on the man’s intellectual disability; it sends the case back so the lower courts can re-evaluate under the guidance in this opinion.

Dissents or concurrances

Two Justices said they would have taken the case for full argument, indicating a preference for further briefing and oral argument rather than this summary disposition.