Supreme Court Reverses Key Ruling on Death Row Inmate’s Intellectual Disability

On Monday, the U.S. Supreme Court overturned a lower court ruling that had protected Joseph Clifton Smith, a man convicted of murder in Alabama, from execution due to findings of intellectual disability. The justices determined that the 11th U.S. Circuit Court of Appeals, based in Atlanta, needs to provide further clarification regarding its decision to vacate Smith’s death sentence.

This decision stemmed from a 1997 murder case and was influenced by the Supreme Court’s 2002 ruling, which stated that executing individuals with intellectual disabilities constitutes cruel and unusual punishment, a violation of the Eighth Amendment of the U.S. Constitution. The Supreme Court’s action emphasizes the need for a more detailed explanation from the appellate court regarding how these legal principles apply to Smith’s case.

Smith was convicted and sentenced to death for the murder of Durk Van Dam in Mobile County, Alabama, in 1997. Evidence presented during the trial revealed that Smith brutally killed Van Dam by beating him with a hammer and a saw to steal his boots, some tools, and $140. The victim’s body was later discovered in his Ford Ranger truck, which was stuck in the mud in a remote wooded area. In 2002, the Supreme Court established a precedent in the case of Atkins v. Virginia that prohibited the execution of individuals with intellectual disabilities.

Like many states, Alabama, which leans conservative, uses an IQ score of 70 or below as a benchmark for assessing intellectual disability. Supreme Court decisions in 2014 and 2017 allowed courts to take into account IQ scores that are slightly above 70, along with other evidence of intellectual disability, including testimonies regarding “adaptive deficits.” Smith had taken five IQ tests, with his lowest score being 72.

A federal judge observed that, considering the standard error margin of plus or minus three points, Smith’s score could potentially be as low as 69. The judge also noted that Smith had experienced significant deficits in social and interpersonal skills, independent living, and academic performance from a young age.

In 2023, the 11th Circuit Court affirmed the judge’s findings and overturned Smith’s death sentence.

“Smith is not intellectually disabled,” Alabama told the Supreme Court in its appeal, contending that the 11th Circuit had “bent law and logic” by focusing too heavily on the Smith’s lowest IQ score to find he was intellectually disabled.

In a short, unsigned opinion issued on Monday, the justices noted that the 11th Circuit’s assessment of Smith’s IQ scores could be interpreted in two different ways and needs further clarification. They stated that the Supreme Court’s consideration of the state’s appeal in the case “may depend on the rationale” behind the 11th Circuit’s ruling.

Conservative Justices Clarence Thomas and Neil Gorsuch expressed their willingness to hear and schedule arguments for Alabama’s appeal. The Supreme Court deliberated for an unusually extended period on whether to accept Alabama’s appeal, which was submitted in August 2023.