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Supreme Court Dismisses Appeal, Leaving Joseph Clifton Smith Protected From Execution

A procedural dismissal on May 21 spares Smith and leaves unresolved how courts should weigh borderline IQ scores against life‑long adaptive deficits.

Overview

  • The Supreme Court on Thursday dismissed Alabama’s appeal, leaving in place lower-court rulings that found Joseph Clifton Smith intellectually disabled and ineligible for the death penalty.
  • Lower courts reached that outcome after considering five IQ tests that ranged from 72 to 78 and expert evidence about Smith’s lifelong deficits, with judges noting that standard error in IQ testing can put a score below the commonly used 70 threshold.
  • Justices Sonia Sotomayor, Elena Kagan, Ketanji Brown Jackson and Justices Brett Kavanaugh and Amy Coney Barrett joined the dismissal, while Chief Justice John Roberts and three other conservative justices dissented.
  • The Trump administration’s Justice Department had backed Alabama’s position that states may set disability standards, but major mental health groups told the court that diagnoses must include adaptive‑function and developmental history, not just raw IQ numbers.
  • The ruling spares Smith from execution but leaves open a broader legal gap: lower courts must still decide how to apply holistic assessments in borderline IQ cases, a question that could affect other death‑penalty cases and access to disability services.