Moore v. Texas

When evaluating an individual’s intellectual capacity to enforce the Eighth Amendment’s prohibition of the execution of intellectually disabled individuals, a State must look to the medical community’s diagnostic framework.

Petitioner was convicted of capital murder and sentenced to death for fatally shooting a store clerk during a botched robbery. Petitioner challenged his death sentence on the ground that he was intellectually disabled. A state habeas court determined that Petitioner was intellectually disabled and thus exempt from execution because Petitioner’s death sentence violated the Eight Amendment’s proscription of cruel and unusual punishments. The Texas Court of Criminal Appeals (CCA) did not adopt the judgment recommended by the habeas court. While the habeas court relied on current diagnostic standards used in the medical community to determine Petitioner’s intellectual disability, the CCA endorsed the 1992 edition of the American Association on Mental Retardation (AAMR), which the CCA adopted in Ex Parte Briseno. The AAMR requires that the adaptive deficits be related to the intellectual functioning deficits, and the Briseno court set forth seven factors to consider when evaluating the relatedness requirement. However, the Supreme Court of the United States held that the current views of medical experts in the community is the proper framework to determine intellectual disability. The factors set forth by the CCA in Briseno contained no citation to any medical or judicial authority and advanced lay perceptions of intellectual disability. By relying on Briseno, the CCA determined that Petitioner failed to prove below average intellectual functioning. However, the CCA failed to account for the IQ test’s standard error of measurement, which would put Petitioner in the clinical range of intellectual disability. In addition, in considering Petitioner’s adaptive functioning, the CCA overemphasized Petitioner’s adaptive strengths when the test focuses on adaptive deficits. The CCA erroneously concluded that Petitioner’s traumatic life experiences indicated that intellectual and adaptive deficits were not related. In the medical community, such traumatic experiences are risk factors for intellectual disability.