In the Hamm case,
That leaves Smith free from execution. As the lower federal courts decided. No need to interfere when lower courts are in agreement.
Supreme Court last term sent the case of Joseph Smith back for the lower court to clarify the basis for its decision. The district court had held that Smith had shown that he was intellectually disabled, and on remand the Eleventh Circuit upheld the district court’s ruling.
Alito writes that in dismissing the case without deciding it, “the Court shies away from its obligation to provide workable rules for capital cases. In doing so, the Court disserves its own death-penalty jurisprudence, States’ criminal-justice systems, lower courts, and victims of horrific murders.”
This case was per curiam with no dissents.