Moore v. Texas

Background

A man on Texas’s death row challenged the state courts’ finding that he was not intellectually disabled and therefore eligible for execution. The trial court had found he was intellectually disabled and thus ineligible for the death penalty. The Texas Court of Criminal Appeals reversed that finding, and this Court previously vacated that reversal and sent the case back for reconsideration under contemporary medical standards.

Reasoning

On remand the Texas court again concluded the man was not intellectually disabled, emphasizing his apparent strengths and improvements in prison and invoking factors similar to older Texas rules. Reviewing the record, the Supreme Court found that the appeals court repeated the same errors this Court had already condemned — overemphasizing adaptive strengths, relying on prison-developed abilities, and hewing to lay stereotypes instead of current clinical guidance. The Court concluded the trial record shows the man has intellectual disability and reversed the appeals court’s judgment.

Real world impact

The ruling directs Texas courts to follow contemporary clinical diagnostic frameworks and not to rely on outdated “Briseno” factors or prison-based improvements when judging intellectual disability. The decision reverses the appeals court and remands the case for further proceedings consistent with this opinion, affecting this defendant and guiding future disability assessments in capital cases.

Dissents or concurrances

Chief Justice Roberts agreed the state court misapplied prior guidance and joined the reversal. Justices Alito, Thomas, and Gorsuch dissented, arguing the Court should not substitute its own factfinding or summarily reverse.