Episode
Opinion Summary: Hamm v. Smith | SCOTUS Declines to Dig into IQ Score Showdown
- Podcast
- The High Court Report
- Published
- May 27, 2026
- Duration seconds
- 1310
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Summary
Hamm v. Smith | Case No. 24-872 | Decided: May 21, 2026 | Docket Link: Here Overview: Death penalty case examining how courts evaluate multiple IQ scores when determining intellectual disability under Atkins. Court dismissed writ as improvidently granted after oral argument revealed parties never litigated the question below. Question Presented: Whether and how courts may consider the cumulative effect of multiple IQ scores in assessing Atkins claims. Posture: Eleventh Circuit affirmed District Court finding Smith intellectually disabled using holistic approach. Main Arguments: Alabama (Petitioner): (1) Courts must combine multiple IQ scores using statistical methods to determine whether defendant proves IQ of 70 or below by preponderance; (2) Standard error of measurement applies equally in both directions, preventing reliance solely on lowest score's error range; (3) Holistic approaches that consider adaptive functioning alongside IQ scores improperly expand Atkins protection beyond intellectual functioning threshold. Smith (Respondent): (1) Courts must assess multiple scores holistically, considering measurement error, expert testimony, and other evidence of intellectual functioning together; (2) Hall requires courts to account for standard error when scores fall near the threshold; (3) Professional standards recommend clinical judgment considering all available evidence rather than mechanical statistical formulas. Holding: Per curiam opinion dismissed writ of certiorari as improvidently granted. Justice Sotomayor wrote concurring opinion joined by Justice Jackson. Justice Thomas dissented. Justice Alito dissented, joined by Justice Thomas, with Justice Gorsuch joining Parts I–III. No substantive ruling on merits. Majority Reasoning: Per curiam provided no reasoning…