[JURIST] The US Supreme Court [official website] ruled [opinion, PDF] Tuesday in Moore v. Texas [SCOTUSblog materials] that the factors considered by Texas in determining a defendant was not intellectually disabled do not comport with the Eighth Amendment [text] or court precedent. The case arose when Petitioner Bobby James Moore fatally shot a store clerk during a botched robbery when he was 20 years old, and was subsequently convicted of capital murder and sentenced to death. On a habeas challenge, a state court determined that Moore was intellectually challenged, and the death penalty would be cruel and unusual punishment. In making this determination, the court consulted current medical diagnostic standards published by the American Psychiatric Association [official website]. However, the Texas Court of Criminal Appeals [official website] declined to adopt [opinion, PDF] the habeas court’s determination. That court used different standards to find that Moore did not have intellectual deficits, and even if he did, there were alternate causes for such deficits such as drug use and academic failure. The Supreme Court noted that it was wrong for the lower court to disregard current medical diagnostic standards and deviate from clinical standards. Additionally, because mental health professionals recognize that traumatic experiences are risk factors for intellectual disability, the lower court should not have required Moore to show that his intellectual and adaptive deficits were related. In 2014, the court ruled in Hall v. Florida [Oyez backgrounders] that intellectual disability should be “informed by the medical community’s diagnostic framework,” and the Texas court’s decision was in conflict with Hall.
The decision was vacated and remanded to the lower court. The court heard oral argument [transcript, PDF; JURIST report] on this case in November. Justice Ruth Bader Ginsburg delivered the majority opinion, joined by four other justices. Chief Justice John Roberts filed the dissenting opinion.