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

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

The Court has now given direction on how multiple IQ scores should be evaluated in Atkins cases, shaping how intellectual disability claims are reviewed in capital litigation.

Case status

Current stage
Decided
Latest event
Decision released May 21, 2026
Case Accepted
Arguments HeardDec 10, 2025
Decision ReleasedMay 21, 2026
What it's about

The Court is deciding how to assess intellectual disability claims in death penalty cases when a defendant has taken multiple IQ tests with varying results. The case could affect how states evaluate Eighth Amendment protections against executing intellectually disabled individuals.

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

Briefing

What it's about

The Supreme Court released a decision in a death penalty case about how courts should assess several IQ test results when deciding whether a person is intellectually disabled under Atkins v. Virginia. The dispute centered on how to weigh mixed scores when some results may support an intellectual disability claim and others may not.

Vote

The Court decided the case, but the prompt does not provide the vote count or opinion lineup.

Impact

The ruling affects capital cases in which a defendant has taken multiple IQ tests with different results. It matters for death row prisoners, state courts, and corrections officials who must apply the Eighth Amendment bar on executing intellectually disabled people.

What's next

Lower courts and state officials must now apply the Supreme Court's instructions in cases involving mixed IQ test results. Lawyers in pending death penalty cases will likely cite this decision as they litigate intellectual disability claims.

What was the core dispute in Hamm v. Smith?

The case asked how courts should evaluate several IQ tests with different results. The question was how those scores should be considered under Atkins v. Virginia.

Who is most affected by this decision in the real world?

Death row prisoners raising intellectual disability claims are directly affected. State trial courts, appellate courts, and corrections agencies also must follow the Court's new guidance.

What happens next procedurally after the Supreme Court's decision?

Lower courts must apply the new rule in this and similar cases. Attorneys and judges will use the decision in future disputes over mixed IQ test results.

Decision

Decision record

What the Court decided

The Court has now given direction on how multiple IQ scores should be evaluated in Atkins cases, shaping how intellectual disability claims are reviewed in capital litigation.

Impact

The ruling affects capital cases in which a defendant has taken multiple IQ tests with different results. It matters for death row prisoners, state courts, and corrections officials who must apply the Eighth Amendment bar on executing intellectually disabled people.

Not official Court text.

Vote

Vote split
2-4
Majority author
Per Curiam

Other opinions

Opinion documents