Hamm v. Smith (No. 23-167)
Summary
The Supreme Court case Hamm v. Smith (2024) concerns the intellectual disability claim of Joseph Clifton Smith, a death row inmate. The District Court vacated Smith's death sentence based on IQ scores, and the Eleventh Circuit affirmed. The Supreme Court vacated the Eleventh Circuit's judgment and remanded the case for clarification on how multiple IQ scores should be evaluated in determining intellectual disability.
Expected Effects
The Eleventh Circuit must clarify whether it applied a per se rule regarding the standard error of measurement for IQ scores or a more holistic approach. This clarification will impact how Smith's intellectual disability claim is assessed. Ultimately, this could affect whether Smith's death sentence is reinstated or if he is deemed ineligible for the death penalty due to intellectual disability.
Potential Benefits
- Ensures consistent application of legal standards for determining intellectual disability in capital cases.
- Promotes a more thorough evaluation of evidence, including expert testimony, in assessing intellectual functioning.
- Upholds the principle that individuals with intellectual disabilities should not be subject to the death penalty, as established in Atkins v. Virginia.
- Provides guidance to lower courts on how to interpret and apply Supreme Court precedent on intellectual disability claims.
- Reinforces the importance of considering the standard error of measurement when evaluating IQ scores.
Potential Disadvantages
- Delays the final resolution of Smith's case, prolonging uncertainty for all parties involved.
- May increase the workload for the Eleventh Circuit, requiring additional analysis and explanation of its decision.
- Could lead to further litigation if the Eleventh Circuit's clarification is still contested.
- Potentially creates confusion if the Supreme Court's guidance is not sufficiently clear.
- May not fully resolve the broader debate on how to assess intellectual disability in capital cases.
Constitutional Alignment
This case primarily concerns the Eighth Amendment's prohibition against cruel and unusual punishment, as interpreted in Atkins v. Virginia. Atkins held that executing individuals with intellectual disabilities violates the Eighth Amendment. The Supreme Court's decision in Hamm v. Smith seeks to ensure that the Eleventh Circuit's evaluation of Smith's intellectual disability claim is consistent with this constitutional principle. The remand aims to clarify the application of legal standards, not to overturn established constitutional rights.
Impact Assessment: Things You Care About ⓘ
This action has been evaluated across 19 key areas that matter to you. Scores range from 1 (highly disadvantageous) to 5 (highly beneficial).