The Supreme Court of the United States has dismissed the case of Hamm v. Smith (Docket No. 24-872), a decision that could have significant implications for how courts assess claims of intellectual disability in death penalty cases. The ruling, issued on May 21, 2026, affects individuals like Joseph Clifton Smith, who has been on death row for over two decades.

The case centers on the question of whether Smith, who was convicted of first-degree murder in 1998, is intellectually disabled and thus ineligible for execution under the Eighth Amendment. Smith's legal team argued that his IQ scores, which ranged from 72 to 78, indicate he meets the criteria for intellectual disability. The Supreme Court's dismissal means that lower courts will not receive explicit guidance on how to evaluate multiple IQ scores in such cases.

This dismissal follows years of legal battles over Smith's mental capacity and the standards for determining intellectual disability in capital punishment cases. The decision has broad implications for other individuals facing similar circumstances across the United States, particularly in states that have adopted strict criteria for intellectual disability evaluations.

Background

Joseph Clifton Smith was convicted in 1998 for the murder of a 74-year-old man. During his sentencing, he presented evidence of intellectual disability, including an IQ score of 72. His legal team also pointed to previous IQ tests that indicated scores of 75 and 74, along with testimony from experts suggesting that his true intellectual functioning could be significantly lower due to the standard error of measurement associated with IQ tests.

In the years following his conviction, the Supreme Court ruled in Atkins v. Virginia (2002) that executing individuals with intellectual disabilities violates the Eighth Amendment. This landmark decision left it to states to define the criteria for intellectual disability. Following this, Alabama established a standard requiring defendants to prove three prongs for intellectual disability: significantly subaverage intellectual functioning, significant deficits in adaptive behavior, and evidence of these issues manifesting before the age of 18.

Smith sought postconviction relief in Alabama state courts, claiming he met these criteria. Initially, his petition was denied, but the Eleventh Circuit Court of Appeals later reversed this decision, stating that the lower court had improperly deferred to previous rulings. The case was sent back to the District Court for a de novo inquiry into Smith's intellectual disability.

The Ruling

The Supreme Court ruled to dismiss the writ of certiorari as improvidently granted. This means that the Court decided not to take further action on the case, effectively leaving the lower court's decision intact without providing any additional guidance on how courts should evaluate multiple IQ scores. The ruling was issued per curiam, meaning it was delivered in a collective voice rather than attributed to a specific justice.

Justice Sonia Sotomayor, joined by Justice Ketanji Brown Jackson, concurred in the decision. She emphasized that the Court was not able to provide meaningful guidance on how courts should analyze multiple IQ scores due to the lack of a clear record and the complex nature of the issues involved. Sotomayor noted, "The Court is not equipped in this case to provide any meaningful guidance on how courts should assess multiple IQ scores." This highlights the challenges courts face in interpreting the implications of varying IQ test results.

Impact

The dismissal of Hamm v. Smith has significant implications for individuals on death row who claim intellectual disability. Without clear guidance from the Supreme Court, lower courts may continue to struggle with how to evaluate multiple IQ scores and the broader context of intellectual functioning. This decision could lead to inconsistencies across different jurisdictions, as states may adopt varying standards for assessing intellectual disability claims.

Moreover, the ruling may impact future cases involving similar claims, as it leaves unresolved questions about how courts should weigh multiple IQ scores and what constitutes sufficient evidence of intellectual disability. The absence of a definitive ruling means that states may continue to implement their own standards, potentially leading to further legal challenges and appeals in the future.

What's Next

While the Supreme Court has dismissed this case, Smith's legal team may still explore other avenues for appeal or seek relief through state courts. Additionally, the lack of a clear ruling on the standards for assessing intellectual disability in capital cases may prompt future litigation as defendants challenge their sentences based on evolving interpretations of mental capacity and the Eighth Amendment.