Framing Analysis
The Supreme Court dismissed Hamm v. Smith as improvidently granted, leaving intact a lower-court ruling that recognized Alabama death-row inmate Joseph Clifton Smith as intellectually disabled under Atkins v. Virginia and spared his life. Six justices joined concurring or dissenting opinions, including Justice Sotomayor’s concurrence and dissents from Justices Thomas and Alito. The case centered on Smith’s IQ and eligibility for the death penalty.