Hamm v. Smith: Oral Argument

Case Summary: Hamm v. Smith involves Alabama death-row prisoner Joseph Clifton Smith, who was convicted of capital murder for killing Durk Van Dam during a 1998 robbery and sentenced to death. Over the years, Smith received five full-scale IQ scores ranging from roughly 72 to 78 (with measurement error meaning his IQ could be as low as about 69), and he sought state postconviction and then federal habeas relief arguing that, under Atkins v. Virginia, his intellectual disability makes him categorically ineligible for execution. After state courts rejected his claim without an evidentiary hearing, the federal district court held a hearing, found he met Alabama’s criteria for intellectual disability, and vacated his death sentence, a ruling the Eleventh Circuit affirmed. The issue before the Supreme Court was whether the Eleventh Circuit used the correct legal standard under the Antiterrorism and Effective Death Penalty Act (AEDPA) when it granted habeas relief by deferring to the federal district court’s factfinding, rather than to the Alabama courts’ rejection of Smith’s Atkins intellectual‑disability claim. In particular, the case asks how federal courts should apply AEDPA’s deference provisions when state courts have denied an Atkins claim without an evidentiary hearing but a federal court later holds a hearing and finds the prisoner intellectually disabled