Law School Case Brief
Moore v. Texas - 137 S. Ct. 1039 (2017)
The Eighth Amendment prohibits cruel and unusual punishments, and reaffirms the duty of the government to respect the dignity of all persons. To enforce the U.S. Constitution's protection of human dignity, a court looks to the evolving standards of decency that mark the progress of a maturing society, recognizing that the Eighth Amendment is not fastened to the obsolete.
Plaintiff Bobby James Moore was sentenced to death for fatally shooting a store clerk during a botched robbery that occurred when he was 20 years old. In habeas corpus proceedings in Texas state court, it was determined that Moore qualified as intellectually disabled and that his death sentence therefore violated the Eight Amendment proscription against "cruel and unusual punishments." On the State's appeal, the Texas Court of Criminal Appeals refused to follow the trial court's habeas corpus recommendation. Moore was granted a writ of certiorari.
Did the imposition of the death sentence violate Moore's Eight Amendment rights?
The Supreme Court of the United States vacated the judgment of the Texas Court of Criminal Appeals and remanded the case for further proceedings. The Court ruled that the state appeals court improperly rejected the finding that Moore was intellectually disabled under current medical diagnostic standards so as to preclude the death penalty. Moore's IQ fell below the established standard, and the state appellate court overemphasized Moore's adaptive strengths rather than focusing on considerable objective evidence of his adaptive weaknesses. The state appellate court erred by applying judicially created non-clinical standards based on lay stereotypes of intellectual disability rather than applying medical diagnostic standards.
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