The U.S. Supreme Court on Thursday dismissed Alabama’s bid to move forward with the execution of Joseph Clifton Smith, a death-row inmate whom lower courts found to be intellectually disabled, according to the Associated Press. The court did not issue a decision on the merits, and its unusual dismissal left the last ruling from lower courts in place.
Smith, 55, has been on death row for roughly half his life after a 1997 conviction for beating a man to death, the AP reported. Alabama had asked the Supreme Court to allow the execution despite those lower-court rulings, setting up a dispute centered on how courts should treat “borderline” intellectual-disability claims when IQ testing results land slightly above a commonly cited threshold.
The Supreme Court’s protection for intellectually disabled people from execution traces to a 2002 landmark ruling, which the AP said the justices relied on in describing the constitutional bar. In later cases in 2014 and 2017, the court held that states should consider other evidence of disability in borderline situations because of the margin of error in IQ tests.
In Smith’s case, the issue concerned what happens when a person has multiple IQ scores that are slightly above 70, the AP said. The AP reported that Smith had five IQ tests producing scores ranging from 72 to 78. His lawyers said he had been placed in learning-disabled classes and dropped out of school after seventh grade, and they also said that at the time of the crime his abilities corresponded to what they described as a kindergarten level in math, a third-grade level in spelling, and a fourth-grade level in reading.
The justices had taken up the case, Hamm v. Smith, to consider how courts should handle those borderline intellectual-disability scenarios, with arguments held in December, the AP reported. Instead of issuing a decision, the Supreme Court dismissed the appeal, a procedural outcome that maintained the lower courts’ conclusions that Smith could not be executed.
The AP said the majority that voted to dismiss the case consisted of the three liberal justices along with Justices Brett Kavanaugh and Amy Coney Barrett. The other four conservative justices dissented, the AP reported, contending that the U.S. Court of Appeals for the 11th Circuit in Atlanta had improperly analyzed the intellectual-disability issue and arguing that their colleagues should have ordered further review of Smith’s case.
The Supreme Court’s dismissal means Alabama’s challenge did not change the legal status of Smith’s death sentence, and the lower-court rulings barring execution remained the controlling outcome after Thursday’s order.