SCOTUS Dismisses Alabama Death Sentence Case In Divided Ruling

The justices later expanded on that standard in decisions issued in 2014 and 2017, directing states to consider broader evidence of intellectual disability in close cases because IQ testing carries a recognized margin of error.

At the center of Smith’s case is how courts should evaluate defendants whose IQ scores fall slightly above the commonly recognized threshold of 70 associated with intellectual disability. Smith received five IQ test scores ranging from 72 to 78.

According to his attorneys, Smith was placed in special education classes for students with learning disabilities and left school after seventh grade.