By Andrew Chung

(Reuters) – The U.S. Supreme Court on Monday rejected a court ruling that spared a man convicted of murder in Alabama from execution because he was found to have an intellectual disability.

The justices concluded that the 11th U.S. Circuit Court of Appeals in Atlanta must clarify its ruling that Joseph Clifton Smith’s death sentence for a 1997 murder should be overturned in light of the Supreme Court’s 2002 decision that the execution of a persons with intellectual disabilities is cruel and unusual punishment prohibited by the Eighth Amendment to the US Constitution.

Smith was convicted and sentenced to death for the 1997 killing of a man named Durk Van Dam in Alabama’s Mobile County. Smith beat the man to death with a hammer and saw him to steal his boots, some tools and $140, according to evidence in the case. The victim’s body was found in his muddy Ford Ranger truck in a secluded wooded area.

Supreme Court precedent from 2002 in a case called Atkins v. Virginia prohibited the execution of people with intellectual disabilities.

Like many states, conservative-leaning Alabama considers evidence of intelligence quotient (IQ) test scores of 70 or lower as part of the standard for determining intellectual disability. Supreme Court rulings in 2014 and 2017 allowed courts to consider IQ score ranges that are close to 70 along with other evidence of intellectual disability, such as testimony of “adaptive deficits.”

Smith had five IQ test scores, the lowest of which was 72. A federal judge noted that Smith’s score could be as low as 69, given the standard of error of plus or minus three points. The judge then found that Smith had significant deficits from an early age in social and interpersonal skills, independent living and academics.

The 11th Circuit upheld the judge’s findings in 2023, overturning Smith’s death sentence.

“Smith is not intellectually disabled,” Alabama told the Supreme Court on appeal, arguing that the 11th Circuit “inverted the law and logic” by focusing too much on Smith’s lowest IQ score to find that he was with intellectual disabilities.

The justices in a brief, unsigned opinion Monday said the 11th Circuit’s assessment of Smith’s IQ scores could be read two ways and needed clarification. The Supreme Court’s review of the state’s appeal in question “may depend on the basis” of the 11th Circuit’s decision, according to the opinion.

Conservative Justices Clarence Thomas and Neil Gorsuch said they would take over and schedule arguments in Alabama’s appeal.

The Supreme Court spent an unusually long time considering whether to accept Alabama’s appeal, which was filed in August 2023.

(Reporting by Andrew Chung in New York; Editing by Will Dunham)