Overview
- The Supreme Court dismissed the case on Thursday, May 21, 2026, leaving in place a district court and the 11th Circuit ruling that Joseph Clifton Smith is intellectually disabled and therefore ineligible for execution.
- Justices Sonia Sotomayor and Ketanji Brown Jackson wrote that the record was not suitable for setting a national rule on how to combine or weigh multiple IQ tests.
- The factual dispute involved five IQ scores for Smith ranging from 72 to 78 and the tests’ standard error of measurement, which can place a low score near or below the 70 threshold used in Atkins cases.
- Four conservative justices dissented, with Justice Samuel Alito arguing the Court should have provided a clear method for calculating a defendant’s ‘true’ IQ and Justice Clarence Thomas urging that Atkins v. Virginia be overruled.
- Disability advocates and legal experts warned the outcome preserves protections against executing people with intellectual disabilities but leaves legal uncertainty for lower courts and could prompt future petitions seeking a uniform rule.