Hamm v. Smith · ¶59
Moreover, the District Court's holistic analysis comports with Alabama law, which has no statute or Alabama Supreme Court decision prescribing how courts must consider multiple IQ scores. See Thomas v. Allen, 607 F. 3d 749, 757 (CA11 2010) (“There is no Alabama case law stating that a single IQ raw score, or even multiple IQ raw scores, above 70 automatically defeats an Atkins claim when the totality of the evidence (scores) indicates that a capital offender suffers subaverage intellectual functioning”). Alabama appellate courts instead recognize that “a court should look at all relevant evidence in assessing an intellectual-disability claim and that no one piece of evidence, such as an IQ test score, is conclusive as to intellectual disability.” Reeves v. State, 226 So. 3d 711, 729 (Ala. Crim. App. 2016). “Conficting expert testimony” with respect to an Atkins claimant's intellectual…Read in context ›
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