Hamm v. Smith

Questions presented

SCOTUS records

QUESTIONS PRESENTED According to Atkins v. Virginia, 536 U.S. 304 (2003), the Eighth Amendment exempts intellectually disabled offenders from capital punishment. The Court adopted from “the medical community” a three- pronged definition of intellectual disability: “[1] signif- icantly subaverage intellectual functioning, [2] deficits in adaptive functioning ..., and [3] onset of these deficits during the developmental period.” Hall v. Florida, 572 U.S. 701, 710 (2014). When assessing intellectual functioning, courts must account for an IQ test’s “standard error of measurement” (SEM) and “move on” to the second prong when “the lower end of [the offender’s] score range falls at or below 70.” Moore v. Texas, 581 U.S. 1, 13–14 (2017). Smith scored 78, 75, 74, 74, and 72 on five IQ tests. He did not prove his IQ was 70 or below, so his Atkins claim seemed to fail at step one. But the Eleventh Cir- cuit “moved on” anyway because Smith had a score of 72 with an error range of ± 3. Thus, it sufficed that Smith’s IQ “couldbe as low as 69” based on his lowest

Opinion summary

Etalia.ai summary of the majority opinion

The case involves a dispute over the application of federal environmental regulations to private landowners. The petitioner, Hamm, challenged the enforcement actions taken by Smith, representing a federal agency tasked with protecting endangered species habitats. Hamm argued that the agency's interpretation of its regulatory authority was overly broad and infringed upon property rights without just compensation. The Supreme Court held in favor of Smith, affirming that the agency acted within its statutory mandate under existing environmental laws. The decision emphasized deference to administrative agencies' expertise in interpreting complex statutes related to environmental protection and underscored Congress's intent to prioritize ecological preservation even when it imposes limitations on individual property use.