Hamm v. Smith · ¶158

The Eleventh Circuit attempted to justify its approach by citing Hall and Moore. On its reading of those cases, any time that the lower bound of a defendant's lowest score descends to 70 or below, IQ cannot be dispositive, and courts must decide an Atkins claim based on evidence of the defendant's adaptive functioning. 67 F. 4th, at 1348–1349 (“Hall and Moore required the district court to turn to evidence of Smith's adaptive defcits because the lower end of his standard-error range was 69”). But as we recognized the last time that this case was before us, neither Hall nor Moore established any rules for analyzing multiple IQ scores, much less the one-low-score approach that the Eleventh Circuit took. Hamm, 604 U. S., at 2 (“This Court has not specified how courts should evaluate multiple IQ scores” (citing Hall, 572 U. S., at 714, and Moore, 581 U. S., at 1)).

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