Moore v. Texas
Headline: Court blocks Texas court’s use of outdated Briseno factors, vacates its judgment, and requires medical-community standards to decide intellectual disability for death-penalty cases, protecting vulnerable defendants from execution.
Holding: The Court vacated the Texas appeals court’s decision, holding that courts must use current medical diagnostic standards—not the Briseno factors—to determine intellectual disability and whether someone is exempt from execution.
- Bars use of Texas’s Briseno factors to restrict intellectual-disability findings in death cases.
- Requires courts to follow current medical diagnostic standards when assessing intellectual disability.
- May prompt vacatur or new review of some death sentences based on updated disability evidence.
Summary
Background
A man convicted of killing a store clerk was sentenced to death and later claimed he was intellectually disabled and therefore exempt from execution. A state fact-finding court that reviewed his case relied on current medical manuals (AAIDD-11 and DSM-5) and recommended relief, but the Texas appeals court rejected that recommendation and instead applied older, state-created Briseno factors.
Reasoning
The core question was whether the Texas appeals court could rely on the Briseno factors instead of contemporary medical guidance to decide intellectual disability. The Court held that Atkins and Hall require courts to be informed by the medical community’s diagnostic framework. The Court found the Briseno factors untied to current clinical standards and said they risk executing persons with intellectual disability. The Court also explained that IQ testing must account for the test’s standard error of measurement and that courts must consider adaptive deficits under modern clinical practice. For these reasons, the Court vacated the Texas court’s judgment and sent the case back for further proceedings consistent with medical standards.
Real world impact
The ruling prevents Texas courts from using the Briseno factors to narrow who qualifies as intellectually disabled in death cases and requires judges to consider current medical evidence and expert views. The decision may lead to renewed review of some death sentences where updated disability evidence was discounted.
Dissents or concurrances
The dissent argued the Court overstepped by relying mainly on clinical consensus rather than state practices and would have upheld the Texas court’s independent factfinding.
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