The U.S. Supreme Court on Thursday dismissed Alabama’s bid to execute Joseph Clifton Smith, a 55-year-old death-row inmate whose intellectual disability has been recognized by state and federal courts. The unsigned order, issued over apparent dissent, leaves in place lower-court decisions that determined Smith to be ineligible for the death penalty under the court’s landmark 2002 ruling in Atkins v. Virginia, which prohibited the execution of people with intellectual disabilities.
Smith was convicted in 1997 of beating a man to death and has spent roughly half his life on death row. His case reached the high court after Alabama sought to overturn lower-court findings that Smith’s intellectual functioning fell below constitutional thresholds. The state argued that Smith’s IQ scores—which ranged from 72 to 78 across five tests—placed him above the commonly cited cutoff of 70 and that the courts had erred in considering additional evidence of disability.
The justices have repeatedly held, however, that states must look beyond a single IQ number when assessing whether a capital defendant is intellectually disabled. In Hall v. Florida (2014) and Moore v. Texas (2017), the court said the margin of error in IQ tests and the individual’s adaptive functioning must be weighed. Thursday’s dismissal effectively reaffirms that standard, declining Alabama’s invitation to revisit the issue.
Smith’s lawyers presented extensive evidence of adaptive deficits. He had been placed in learning-disabled classes and dropped out of school after seventh grade. At the time of the 1997 crime, he performed math at a kindergarten level, spelled at a third-grade level, and read at a fourth-grade level, according to court records cited by his attorneys.
Alabama had pressed the justices to narrow the scope of the Atkins protection, arguing that an IQ score consistently above 70 should preclude a finding of intellectual disability regardless of other evidence. The state’s appeal, which the Supreme Court dismissed without a full hearing, would have allowed it to proceed with Smith’s execution.
The decision was not accompanied by a signed opinion and the court’s order did not detail the vote. Mark Sherman of the Associated Press reported that the court was divided, with at least one or more justices dissenting from the dismissal.
Smith’s case has drawn attention as part of a broader national reconsideration of how courts evaluate intellectual disability claims in capital cases. A 2021 study published in the Journal of the American Academy of Psychiatry and the Law found that states vary widely in their application of the Atkins standard, with some jurisdictions relying almost exclusively on IQ scores while others incorporate adaptive functioning evidence. The Supreme Court’s decision to leave the lower-court rulings intact reinforces the requirement that judges examine the full clinical picture.
The dismissal does not change Smith’s underlying conviction; he remains imprisoned on a life sentence unless Alabama successfully resentences him to death through another legal avenue.