Hamm v. Smith · ¶27
To start, and most significantly, the parties agree that there is no single approach to weighing multiple IQ scores. Alabama here disclaims any “single, mechanical rule . . . for aggregating multiple IQ scores.” Reply Brief 12 (internal quotation marks omitted; ellipsis in original). It instead offers a rule that a factfnding court must consider the “cumulative effect” of multiple IQ scores, by which it means that the scores must be “combine[d] to prove an IQ of 70 or below.” Id., at 1, 10. Alabama suggests that courts could do so using one of several methods, such as taking the median, examining the “overlap among each score's error range,” calculating a composite score, taking the average, or looking only at the highest score. Id., at 10–12, 19. Still, it acknowledges that there is no “consensus over whether and how to evaluate the cumulative effect of multiple IQ scores.” Brief for…Read in context ›
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