Moore v. Texas (2017)

Moore v. Texas, 137 S. Ct. 1039 (2017), is a United States Supreme Court decision about the death penalty and intellectual disability. The court held that contemporary clinical standards determine what an intellectual disability is, and held that even milder forms of intellectual disability may bar a person from being sentenced to death due to the Eighth Amendment's prohibition against cruel and unusual punishment. The case clarified two earlier cases, Atkins v. Virginia (2002) and Hall v. Florida (2014).

Moore v. Texas
Supreme Court of the United States
Argued November 29, 2016
Decided March 28, 2017
Full case nameBobby James Moore, Petitioner v. Texas
Citations581 U.S. ___ (more)
137 S. Ct. 1039; 197 L. Ed. 2d 416
ArgumentOral argument
Case history
PriorEx parte Moore, 470 S.W.3d 481 (Tex. Crim. App. 2015); cert. granted, 136 S. Ct. 2407 (2016).
SubsequentEx parte Moore, 548 S.W.3d 552 (Tex. Crim. App. 2018); reversed and remanded, Moore v. Texas, 586 U.S. ___ (2019)
Holding
When deciding if an inmate on death row is qualified as "intellectually disabled", as under Atkins v. Virginia (2002), courts may not ignore dominant medical guidelines. Texas Court of Criminal Appeals reversed and remanded.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Samuel Alito · Sonia Sotomayor
Elena Kagan
Case opinions
MajorityGinsburg, joined by Kennedy, Breyer, Sotomayor, Kagan
DissentRoberts, joined by Thomas, Alito
Laws applied
U.S. Const. Amend. VIII

Background

Case background

On April, 1980, Bobby James Moore committed armed robbery in Houston, Texas.[1]: 788  He shot and killed James McCarble, and was subsequently charged for capital murder – a crime punishable by death.[2][1]: 788–789  He was found guilty by a jury and sentenced to death; in 2001, after an appeal, he was again sentenced to death by a jury.[1]: 789  He presented an appeal in 2014, and a hearing was held to determine the existence and scope of his intellectual disability; he had an IQ of just over 70, and the court recommended that his death sentence be either vacated or turned into a life in prison sentence.[1]: 789  The Texas Court of Criminal Appeals (CCA) instead affirmed his death sentence based on the factors laid out in Ex parte Briseno.[upper-alpha 1][1]: 789–790 

In Ford v. Wainwright, 477 U.S. 399 (1986), the Supreme Court invalidated the use of capital punishment for those deemed insane.[1]: 785  Sixteen years later, in Atkins v. Virginia, 536 U.S. 304 (2002), the Supreme Court held that the Eighth Amendment prohibits the use of capital punishment for those with intellectual disabilities.[3]: 1033  They ruled in that case that it constituted cruel and unusual punishment, and it allowed individual states to define intellectual disability.[3]: 1066  States mostly relied on the definitions provided by the American Psychological Association and the American Association on Intellectual and Developmental Disabilities, which generally required for a finding of intellectual disability: that the person has measurable deficit in intelligence; that this deficit impairs certain kinds of social life; and that the deficit emerged prior to adulthood.[3]: 1036–1037 

In 2014, the court invalidated rigid cutoff schemes for defining intellectual disabilities in Hall v. Florida, 572 U.S. 701.[3]: 1048  The lower courts of appeals disagreed on the meaning of Hall; one circuit found that there was no legal definition of intellectual disability, while another said the legal definition was the same as the clinical one.[3]: 1048 

Decision

In a 5–3 decision, Associate Justice Ruth Bader Ginsburg delivered the court's opinion.[3]: 790  The court held that the Briseno factors violated both Atkins and Hall, and subsequently, that they violated the Eighth Amendment's prohibition against cruel and unusual punishment.[3]: 790  In particular, it held that an IQ of 70 was not a rigid cutoff, and that even those with an IQ just above 70 (like Moore) may also be intellectually disabled.[3]: 790  It also held that contemporary and "prevailing clinical standards"—not those from 1992, when Texas created its definition[4]—are those at issue in deciding whether a defendant is eligible for the death penalty, and that mild forms of intellectual disability can preclude a death sentence.[3]: 790  It remanded the case back to the CCA.[5]: 5 

Chief Justice John Roberts dissented, joined by Associate Justices Clarence Thomas and Samuel Alito.[3]: 791  He stated that Texas had considered the "prevailing clinical standards" when it crafted its death penalty scheme, and that states had a right to determine their own schemata for defining intellectual disability.[3]: 791  He also said the court's reliance on clinical standards, and not moral judgments, was at odds with Eighth Amendment jurisprudence.[3]: 791 

Later developments

On remand in 2018, the CCA again sentenced Moore to death.[5]: 5  Moore appealed to the Supreme Court, and they reversed the decision in a per curiam opinion in Moore v. Texas II, 139 S. Ct. 666 (2019).[5]: 5  They held that Moore was ineligible for death because of his intellectual disability; Chief Justice Roberts concurred, while Justices Alito, Thomas, and Gorsuch dissented.[5]: 5, 30 [6]

As of 2021, there were 28 states that still used the death penalty, and 19 of them cited Moore I or II.[5]: 31  Some courts followed Moore I and II clearly, while others did not.[5]: 92 

Notes and references

Notes
  1. The factors included: whether the intellectual disability emerged in childhood; whether the person is impulsive in nature; whether the person is a leader or a follower; whether the person is mostly rational; whether the person can provide false statements easily; and whether the alleged crime was complex and required planning.

References
  1. Dupey, Bridget C. (2018). "Moore v. Texas: The continued quest for a national standard". Denver Law Review. 95 (3): 781–808.
  2. "Ex Parte Bobby James Moore, Applicant NO. WR–13,374–05". FindLaw.
  3. Barker, Clinton M. (April 2017). "Substantial guidance without substantive guides: resolving the requirements of Moore v. Texas and Hall v. Florida". Vanderbilt Law Review. 70 (3): 1027–1070.
  4. Howe, Amy (March 28, 2017). "Opinion analysis: A victory for intellectually disabled inmates in Texas". SCOTUSblog. Retrieved August 22, 2022.
  5. Updegrove, Alexander (2021). "The development of intellectual disabilities in United States capital cases and the modern application of "Moore v. Texas" to state court decisions". University of Massachusetts Law Review. 16 (2): 2–97.
  6. Moore v. Texas, 139 S. Ct. 666 (2019).
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