Moore v. Texas

Under the Eighth Amendment’s protection against cruel and unusual punishment, the State of Texas failed to apply appropriate standards for determining intellectual capacity in relation to capital punishment, which should be informed by current medical standards.

Petitioner killed a store clerk during a robbery. The trial court found Petitioner intellectually disabled and thus ineligible for the death penalty. The Texas Court of Criminal Appeals reversed, holding that Petitioner lacked an intellectual disability while using evidentiary factors from 1992 that cited no medical or judicial authorities. The United States Supreme Court vacated the decision and remanded for further consideration, because the factors lacked grounding in prevailing medical practices. Subsequently, the lower court again held that the Petitioner was not intellectually disabled. Petitioner requested reversal of the decision as contrary to the Supreme Court’s holding. Upon further review, the Court criticized the appellate court for overemphasizing Petitioner’s perceived adaptive strengths, as opposed to the adaptive deficits identified by the trial court. The Court also criticized the persisting reliance upon Petitioner’s adaptive improvements in prison, because the Court’s prior holding cautioned against reliance upon this factor. Next, the Court criticized the opinion’s departure from clinical practice by requiring Petitioner to prove that any deficits in capacity stemmed from an intellectual disability, as opposed to “emotional problems.” Finally, the Court identified instances in the opinion’s language that evinced reliance upon the previous factors deemed unconstitutional. Ultimately, the Court deemed the appellate court’s decision too similar to its prior, improper analysis. REVERSED AND REMANDED.