US Supreme Court leaves Alabama execution block in place for Joseph Clifton Smith

# US Supreme Court leaves Alabama execution block in place for Joseph Clifton Smith

Standfirst: The justices dismissed Alabama’s bid to revive an execution after lower courts found Joseph Clifton Smith intellectually disabled and therefore ineligible for the death penalty.

The US Supreme Court on 2026-05-21 dismissed Alabama’s effort to overturn a ruling that blocked the execution of Joseph Clifton Smith, a death row prisoner found to be intellectually disabled.

In a brief unsigned order, the court threw out the state’s petition in *Hamm v Smith* without deciding the merits. The practical effect was to leave in place the lower-court judgment that Smith cannot be executed under the US Constitution.

The case turned on how courts should evaluate multiple IQ scores that straddle the threshold used in death-penalty eligibility rules, and how much additional evidence of adaptive functioning should be weighed alongside those scores. Alabama had argued that Smith’s scores should be read as too high to qualify him for exemption from capital punishment. The lower courts disagreed, saying the evaluation had to be more holistic.

The Guardian reported that Smith was convicted of a 1997 murder and had five IQ scores ranging from 78 to 72. A federal judge in the 11th Circuit accepted evidence that, even allowing for measurement error, his lowest score could fall below 70 and that he showed significant deficits in everyday functioning from an early age. That evidence included schooling records, social and interpersonal difficulties, and problems with independent living.

The Supreme Court’s action does not rewrite the broader law. A 2002 precedent held that executing an intellectually disabled person violates the Eighth Amendment ban on cruel and unusual punishment, but the court has left states to set the standards for determining who qualifies. Later rulings in 2014 and 2017 allowed courts to consider close IQ ranges together with other evidence of disability.

The latest order keeps the focus on that unresolved middle ground. Alabama had wanted the court to place more weight on the scores that put Smith above the cutoff. The federal courts instead accepted the view that the evidence of adaptive deficits mattered enough to bar execution.

The Guardian said liberal justices Sonia Sotomayor and Ketanji Brown Jackson concurred in the dismissal, while conservative Justices Clarence Thomas and Samuel Alito dissented. Chief Justice John Roberts and Justice Neil Gorsuch joined part of Alito’s dissent. Sotomayor said the lower court’s finding that Smith had significantly subaverage intellectual functioning was at least plausible and argued that the court was not well placed to offer broad new guidance on how multiple IQ scores should be analyzed.

For Alabama, the loss closes a procedural route that had briefly offered a chance to reopen the question of Smith’s eligibility for execution. For the wider death-penalty debate, the case shows that even after the court accepts review, it can still step back and leave lower-court rulings standing.

The result is narrow but consequential: Smith remains protected from execution, and the Supreme Court has declined for now to give states a more aggressive rule for handling mixed IQ evidence in capital cases.