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By Mae Slater on
 November 5, 2024

Supreme Court Mandates Further Review of Alabama Inmate's Intellectual Disability Claim

The Supreme Court has taken decisive action in the case of Joseph Smith, ordering a federal appellate court to revisit the matter of his intellectual disability claims related to his death row conviction in Alabama.

CNN reported that the case underscores ongoing legal challenges surrounding intellectual disability in capital punishment cases, an issue first tackled by the Supreme Court over two decades ago.

Joseph Smith's conviction stems from a 1997 homicide, involving the brutal murder of Durk Van Dam. Smith was found guilty of beating Van Dam to death with a hammer and saw during a robbery for $140 and other items.

His trial court determined that he was intellectually disabled, a conclusion upheld by an appellate court last year.

The complexity of Smith's intellectual disability claim revolves around his IQ score, which is close to 70. This figure places him near the benchmark established by the Supreme Court's 2002 ruling concerning intellectual disabilities in death penalty cases.

The 11th U.S. Circuit Court of Appeals noted that Smith’s IQ score could possibly be even lower, adding further uncertainty to the case.

Joseph Smith's Case in the Courts

Smith's appeal was under review by the Supreme Court for more than a year, suggesting a divide among the justices. The Court's decision to send the case back to the appellate level implies a desire for more clarity on Smith’s intellectual capabilities as assessed by the lower courts.

In a ruling, the Supreme Court highlighted ambiguities in the earlier judgment, stating that the basis for Smith’s intellectual disability decision by the lower court was “unclear on this point and this court’s ultimate assessment.” The court's action reflects its cautious approach in cases involving claims of intellectual disability.

The state of Alabama's description of Smith underscores the severity of his crime. They characterized him as someone who “brutally beat” Van Dam. This portrayal adds a layer of complexity to the consideration of his intellectual capacity claims.

The Supreme Court's engagement with Joseph Smith’s case is part of its broader involvement with similar cases of intellectual disability claims. In 2002, the court deemed it unconstitutional to execute inmates with intellectual disabilities, aligning such actions as violations under the Eighth Amendment.

Recently, the court has shown increased interest in revisiting these guidelines, evidenced by their attention to multiple cases involving this topic. They heard arguments earlier in the month regarding Richard Glossip, another death row inmate from Oklahoma, and agreed to review Ruben Gutierrez’s case from Texas.

This pattern indicates an evolving perspective on the application of the death penalty concerning inmates' intellectual capacities, emphasizing the judiciary's role in shaping criminal justice standards.

Smith's Position and the Broader Implications

Within Smith’s case, the variability of his IQ score emerged as a pivotal concern. The 11th Circuit’s acknowledgment of the potential for Smith’s IQ to fall below 70 further complicates the legal processes determining his fate.

Justices Clarence Thomas and Neil Gorsuch expressed interest in hearing Smith’s case without delay, suggesting some justices may have a differing sense of urgency or perspective regarding the nature and scope of Smith’s intellectual assessments.

The extended deliberations and recent developments highlight the court’s ongoing struggle to resolve such contentious issues, underscoring the difficulties in judicial determinations concerning intellectual disability parameters.

As the Supreme Court requires the federal appeals court to re-examine Smith's case, legal analysts and public stakeholders await what this could mean for future death row cases involving claims of intellectual disability.

The decision could have far-reaching implications not only for Smith but for how courts interpret and apply the 2002 ruling concerning intellectual disabilities in capital punishment settings. It emphasizes the balance the justice system seeks in fair trial practices and protection of disability rights.

The anticipation of more detailed evaluations and the potential emergence of new legal standards regarding intellectual disabilities in capital cases create a significant moment in the interplay between legal frameworks and human rights considerations.

Written By:
Mae Slater

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