In September 2018, the Alabama Supreme Court voted 5-4 to overturn the death sentence of a man convicted in a 2009 robbery and shooting that led to the death of a man. The ruling came after the United States Supreme Court ordered Alabama courts to reconsider the death sentence for Anthony Lane in 2015, stating that states cannot execute individuals with intellectual and developmental disabilities. The Alabama attorney general’s office conceded that the trial court should not have sentenced Lane to death and joined in the defense’s motion.
Atkins v. Virginia
In the case of Atkins v. Virginia, the U.S. Supreme Court held that the execution of individuals with intellectual disabilities violated the Eighth Amendment ban on cruel and unusual punishment. The Court stated that the Eighth Amendment should be read in light on the “evolving standards of decency that mark the progress of a mature society.” The Court cited the fact that a number of states had begun to outlaw the execution of the intellectually disabled and saw a consistency in the direction of change on the issue. The Court left it to the discretion of individual states to set guidelines in determining whether an individual had an intellectual disability that would prevent their execution.
Hall v. Florida
In Hall v. Florida, the U.S. Supreme Court narrowed the standard states may use in determining whether an individual sentenced to death has an intellectual disability that would prevent execution. Florida had established a bright-line rule that anyone with an IQ over 70 was eligible for execution. The Court found that states had to go beyond IQ measurements in determining eligibility and stated that a rigid rule could lead to the execution of individuals with mental disabilities. A defendant must be able to introduce evidence in addition to IQ scores that show things such as the inability to learn basic skills and adapt to changes.
In the Alabama case, Lane had an IQ of 70 and it was undisputed that his intellectual functioning was significantly below average. The dispute in the lower courts centered around whether Lane had the requisite deficits in adaptive skills that would render him intellectually disabled. A medical expert determined that Lane lacked the fundamental social and practical skills that would make him eligible for execution.
If you or a loved one with a mental disability has been arrested or convicted of a crime, you need an experienced criminal defense attorney on your side. Elizabeth Kelley specializes in representing individuals with mental illnesses and intellectual and developmental disabilities. To schedule a consultation call (509) 991-7058.