Alabama Supreme Court Bars Death Penalty for Man with Intellectual DisabilitySeptember 19, 2018

The Alabama Supreme Court on Friday reversed Anthony Lane's death sentence and ordered the trial court to sentence him to life imprisonment without parole after finding that Mr. Lane is intellectually disabled.

Mr. Lane was convicted of capital robbery murder in Jefferson County. Before he was sentenced, the defense presented evidence that he is intellectually disabled and therefore ineligible for a death sentence under the United States Supreme Court's decision in Atkins v. Virginia, which bars the death penalty for people with intellectual disability. The trial court nonetheless sentenced Mr. Lane to death, and the Alabama Court of Criminal Appeals affirmed.

EJI attorneys asked the United States Supreme Court to review Mr. Lane's sentence, and on October 5, 2015, the Court granted Mr. Lane's petition. The Court sent the case back to the Alabama Court of Criminal Appeals for further consideration in light of Hall v. Florida, in which the Court held that sentencing courts must use clinical definitions of intellectual disability. But the Court of Criminal Appeals again affirmed Mr. Lane's death sentence.

EJI appealed to the Alabama Supreme Court, which last week found that Mr. Lane is ineligible for the death penalty because he is intellectually disabled.

Mr. Lane suffered acute respiratory-distress syndrome at birth, which can adversely affect brain development. When Mr. Lane was 11, his mother was murdered, and at 14, his uncle hit him in the head with a shotgun, rendering him unconscious, and broke his arm. The Supreme Court has recognized that traumatic experiences like these put people at risk for intellectual disability.

Medical expert testimony based on interviews with Mr. Lane and his family and various accepted tests established that Mr. Lane has an IQ of 70; he had been developmentally delayed since birth and was in special-education classes throughout his time in school.

Testing also showed significant deficits in adaptive skills: Mr. Lane has deficits in verbal skills; reads and performs math at a third-grade level; has trouble with simple financial transactions; cannot live on his own; has deficits in social relationships and social understanding; does not make use of any available community services; has deficits in overall judgment; and he has never held a job.

The state supreme court also found that the trial court and Court of Criminal Appeals's reliance on facts like Mr. Lane's ability to talk to police and that he had written some rap lyrics did not rebut the expert's testing in any meaningful way. The lower courts also put a lot of weight on how the crime was committed, the Alabama Supreme Court wrote, but there was "nothing particularly sophisticated" about how the crime was committed: no evidence of detailed planning, thoughtful premeditation, or sophisticated advanced preparation.

Evaluating all of the evidence in light of the United States Supreme Court's decisions, and using the established clinical definition of intellectual disability, the Alabama Supreme Court found Mr. Lane ineligible for the death penalty because he is intellectually disabled, and ordered to trial court to sentence him to life without parole.