Supreme Court to Review Alabama’s Death Row Case Concerning IQ Test

Alabama officials sought to execute Joseph Clifton Smith, who was convicted and sentenced to death for a 1997 murder before his sentence was overturned.

The Supreme Court in Washington on April 25, 2024. Mariam Zuhaib/AP Photo

The Supreme Court said on June 6 that it will consider how courts should weigh multiple IQ tests when assessing a death row defendant’s claim of intellectual disability, in a case tied to an Alabama death row inmate.

The court granted Alabama’s petition to clarify whether and how courts should evaluate the “cumulative effect” of multiple intelligence quotient (IQ) scores in assessing an Atkins claim—which prohibits the execution of individuals with intellectual disabilities—according to its website.

Alabama officials sought to execute Joseph Clifton Smith, who was convicted and sentenced to death for a 1997 murder before his sentence was overturned by lower courts because of his intellectual disabilities.

Alabama accepts an IQ score of 70 or below as part of the legal test used to establish a person’s intellectual disability.

According to the court filings, Smith had five IQ test scores, with the lowest being 72—which is above Alabama’s cutoff for an Atkins claim. But lower courts said that Smith’s IQ could be as low as 69 because of measurement errors and that other evidence of mental disability existed.

The 11th U.S. Circuit Court of Appeals upheld the judge’s conclusions in 2023, setting aside Smith’s death sentence. This prompted Alabama officials to file their appeals to the Supreme Court in the case.

In February, Alabama filed a petition asking the Supreme Court to review the lower court’s decision and clarify “how and why courts should conduct an ‘analysis multiple IQ scores jointly’” when evaluating an Atkins claim.

“As the State’s expert testified, five IQ tests provide a more reliable estimate of the test-taker’s true IQ than one test alone,” the petition stated. “Accordingly, a court should account for the conjunction of an offender’s scores, rather than rely on what each score might suggest separately.”

In November 2024, the justices threw out the 11th Circuit’s decision, concluding that the lower court’s evaluation of Smith’s IQ scores can be read two ways and therefore requires clarification.

The 11th Circuit later issued an opinion clarifying that its evaluation was based on “a holistic approach to multiple IQ scores” that also considered additional relevant evidence, including expert testimony.

Alabama argued in its petition filed in August 2023 that Smith “is not intellectually disabled” and that the 11th Circuit “bent law and logic” by paying too much attention to the lowest test score.

The Epoch Times reached out to Smith’s attorney for comment and did not receive a response by publication time.

Reuters and Matthew Vadum contributed to this report.