Case Preview: Hamm v. Smith | IQ Score Showdown: When Multiple Tests Determine Life or Death | Argument Date: 12/10/25
Case Preview: Hamm v. Smith | IQ Score Showdown: When Multiple Tests Determine Life or Death | Argument Date: 12/10/25  
Podcast: SCOTUS Oral Arguments and Opinions
Published On: Wed Nov 19 2025
Description: Hamm v. Smith | Case No. 24-872 | Oral Argument Date: 12/10/25 | Docket Link: HereQuestion Presented: When someone takes multiple IQ tests to prove intellectual disability in a capital case, do courts look at all the scores together, or can one low score alone save their life?OverviewThe Supreme Court will decide whether courts must evaluate multiple IQ scores collectively or whether a single qualifying score triggers constitutional protection in death penalty cases. This decision affects hundreds of current death row inmates and reshapes capital litigation nationwide.Episode RoadmapOpening: Life-or-Death Numbers Game• Decision by June 2025 with immediate nationwide implementation• Smith's five IQ scores (75, 74, 72, 78, 74) create constitutional conflict• Alabama courts denied protection; federal courts granted it based on single low scoreBackground: Murder and Testing Battle• 1997: Smith murdered Van Dam for suspected cash, received death sentence• Federal habeas relief sought based on intellectual disability claim• Five IQ tests created evidentiary puzzle for courtsConstitutional Question• Collective evaluation vs. holistic assessment approaches• State discretion in implementing federal constitutional mandates• Burden of proof when test results create uncertaintyEpisode HighlightsAlabama's Arguments (Supporting Execution):State Discretion• Atkins left states "task of developing appropriate ways to enforce" constitutional prohibition• Supreme Court provided no specific implementation guidelines• Alabama's preponderance standard considering all scores fits constitutional frameworkRejecting "One-Low-Score" Rule• Eleventh Circuit misread precedents, improperly shifted burden to state• Four out of five scores above 70 should control determination• Multiple scores provide more accurate assessment than isolated measurementsNo Constitutional Expansion• Atkins protected only those "known to have IQ under 70"• Extending protection to borderline cases exceeds national consensusSmith's Arguments (Opposing Execution):Holistic Assessment Required• Courts must evaluate scores "holistically" with expert interpretation, not mechanical counting• Hall v. Florida mandates "additional evidence" beyond raw scores• Alabama law requires considering "all relevant evidence"Proper Application• District court correctly held evidentiary hearing and credited Smith's experts• Expert testimony showed measurement error creates genuine uncertainty• Prevents mechanical application of arbitrary cutoffsScientific Reality• IQ tests contain measurement error, particularly for borderline functioning• Constitutional protections require considering scientific testing limitationsUnited States' Arguments (Supporting Alabama):Preserve State Discretion• Atkins preserves "traditional legislative role in setting criminal sanctions"• Maintains federalism principles and constitutional structureMultiple Scores More Reliable• "Multiple IQ scores often say more collectively than any one does alone"• Statistical reliability improves with comprehensive testingPrecedent Limitation• Hall and Moore corrected specific state misuse of IQ tests• Did not mandate "one-low-score rule" as circuits interpretedStakes and ImplicationsImmediate...