Skip to main content

No. 24-872October Term 2025Decided May 21, 2026Updated Sep 2, 2026

Docket 24-872October Term 2025 (2025–2026)

Hamm v. Joseph Clifton Smith

John Q. Hamm, Commissioner, Alabama Department of Corrections, Petitioner v. Joseph Clifton Smith

The Court ended its review without resolving the IQ-score question presented by Alabama and Smith.

Case status

Decided 5-4 · May 21, 2026 · Opinion by Justice Curiam

Read the opinion (PDF)
Current stage
Decided
Latest event
Decision released May 21, 2026
Case Accepted
Arguments HeardDec 10, 2025
Decision ReleasedMay 21, 2026
What it's about

Joseph Clifton Smith, who was sentenced to death in Alabama, argued that he is intellectually disabled and therefore cannot be executed under Atkins v. Virginia. The Supreme Court dismissed the case as improvidently granted, leaving the lower court’s ruling in place and not deciding how courts must weigh several IQ-test scores in assessing an Atkins claim.

Question presented

When a capital defendant has taken multiple IQ tests with varying results, how should courts evaluate the cumulative effect of those scores to determine whether the defendant has significantly subaverage intellectual functioning under Atkins v. Virginia ?

Case path

United States Court of Appeals for the Eleventh Circuit / Decision released May 21, 2026

Area

Capital Punishment

Decision

Decision record

What the Court decided

The Court ended its review without resolving the IQ-score question presented by Alabama and Smith.

Result
Dismissed

Impact

People facing death sentences who claim intellectual disability are directly affected, including Joseph Clifton Smith. The Court dismissed the case as improvidently granted (not the right case to decide the question). For example, Smith’s five IQ scores ranged from 72 to 78. The dismissal created no new Supreme Court method for combining multiple IQ scores. Future courts may continue confronting how to assess such scores under Atkins v. Virginia.

Not official Court text.

Vote

Vote split
5-4
Majority author
Per Curiam

Opinion documents

Briefing

What it's about

The Supreme Court dismissed its writ of certiorari (its decision to hear the case) as improvidently granted. It did not answer how courts should weigh multiple IQ scores in an Atkins intellectual-disability claim.

Vote

The Court ruled 5–4, with Justices Kavanaugh, Kagan, and Barrett in the majority; Justices Sotomayor and Jackson concurred; Chief Justice Roberts and Justices Thomas, Alito, and Gorsuch dissented.

In a per curiam opinion, the Court dismissed the writ of certiorari as improvidently granted.

“The writ of certiorari is dismissed as improvidently granted.”

Justice Per Curiam(majority)

Impact

The case creates no new Supreme Court standard for evaluating varying IQ scores in death-penalty cases. Capital defendants raising intellectual-disability claims, including Smith, remain affected by the legal rules that otherwise apply to their cases.

What's next

The Supreme Court case is over. Lower courts will continue addressing intellectual-disability claims without a new Supreme Court rule from this case on combining multiple IQ scores.

What did the Supreme Court rule in Hamm v. Smith?

The Court dismissed its decision to hear the case as improvidently granted. It did not resolve the question about assessing multiple IQ scores.

Who is affected by the Hamm v. Smith dismissal?

People facing death sentences who raise intellectual-disability claims may be affected. The decision creates no new nationwide method for weighing differing IQ-test results.

What happens next in Hamm v. Smith?

The Supreme Court's review has ended. Lower courts continue to handle Smith's case and similar claims under the legal rules otherwise applicable.

Timing

Decided May 21, 2026

The Court released its decision 162 days after oral argument on December 10, 2025. The median for cases argued in December is 148 days.

Based on 23 merits cases argued in December since 1995.Argument and decision days

Activity

Docket activity7
  • AI analysis generated: Case Briefing

    Sep 2, 2026 | Generated

  • AI analysis generated: Impact Analysis

    Sep 2, 2026 | Generated

  • AI analysis generated: Opinion Summary

    Sep 2, 2026 | Generated

  • Opinion added: Opinion of the Court - Per Curiam

    May 21, 2026 | Court records

  • Brief added: Questions Presented

    Mar 8, 2026 | Court records

  • Audio Recording added: Oral Arguments - Hamm

    Dec 10, 2025 | Court records

  • Brief added: Petition

    Feb 12, 2025 | Court records