Hamm v. Smith

608 U.S. ____ (2026) · Supreme Court of the United States · May 21, 2026 · No. No. 24-872

Summary

The Supreme Court dismissed as improvidently granted a writ of certiorari in a capital case concerning the assessment of intellectual disability under Atkins v. Virginia when a defendant has multiple IQ scores. Justice Sotomayor, joined by Justice Jackson, concurred, explaining that the case was not suitable for establishing a specific methodology for evaluating multiple IQ scores and defending the lower courts’ holistic approach.

Holdings

  1. The writ of certiorari is dismissed as improvidently granted.

Questions Presented

  1. Whether the writ of certiorari should be dismissed as improvidently granted.
  2. Whether and how courts may consider the cumulative effect of multiple IQ scores when assessing an Atkins intellectual-disability claim.

Disposition

dismissed

Cases Cited (18)

  • Atkins v. Virginia, 536 U.S. 304 (2002)(discussed)
  • Hall v. Florida, Hall v. Florida, 572 U.S. 701 (2014)(discussed)
  • Moore v. Texas, 581 U.S. 1 (2017)(discussed)
  • Hamm v. Smith, 604 U.S. 1 (2024) (per curiam)(followed)
  • Penry v. Lynaugh, 492 U.S. 302 (1989)(discussed)
  • Brumfield v. Cain, 576 U.S. 305 (2015)(discussed)
  • Anderson v. Bessemer City, 470 U.S. 564 (1985)(discussed)
  • Thomas v. Allen, 607 F.3d 749 (11th Cir. 2010)(discussed)
  • Reeves v. State, 226 So. 3d 711 (Ala. Crim. App. 2016)(discussed)
  • Anderson v. Bessemer City, 470 U.S. 564 (1985)(discussed)

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