Hamm v. Smith · ¶35

Unsurprisingly, then, neither the District Court nor the Eleventh Circuit specifically addressed whether a court must consider the “cumulative effect” of Smith's IQ scores by combining them using a specific method, or whether one method is better than another, or even how a court should go about deciding which method is preferable. Instead, based on the arguments and evidence raised, the Eleventh Circuit held that the District Court did not err in its “ `holistic' ” consideration of Smith's scores and that its factual determination that Smith has significant subaverage intellectual functioning was not clearly erroneous “based on the complete record, including any relevant expert testimony.” Pet. App. 2a.

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