Hamm v. Smith · ¶135
While Hall affrmed a 70-IQ cutoff for Atkins claims, it imposed a constitutional rule about how courts may apply that cutoff to an IQ test score. At the time of Hall, Florida treated a test score as a “final and conclusive” determination of a defendant's IQ and “refus[ed]” to consider possible measurement error. 572 U. S., at 712. Thus, if a defendant failed to produce a test score of 70 or below, Florida courts rejected Atkins relief without considering any other evidence. Hall rejected Florida's approach. Although Hall acknowledged that sufficiently high scores might be dispositive in some cases, 572 U. S., at 715, the Court held that courts must account for a test's “standard error of measurement,” an estimate of the test's possible error, id., at 723– 724. To do so, courts must interpret an individual test score using a “confidence interval” that captures a range of IQs, rather than…Read in context ›
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