On Monday, the United States Supreme Court overturned an Alabama state court decision affirming Anthony Lane’s death sentence after EJI attorneys argued that evidence of Mr. Lane’s intellectual disabilities made the death penalty unconstitutional in his case.
In a 2002 decision, the Supreme Court held that the Constitution prohibits the execution of a person with intellectual disability, which is defined by three criteria: significantly impaired intellectual functioning or IQ; significant deficits in adaptive behavior; and the emergence of these problems when the person was 18 or younger.
In 2011, Anthony Lane was convicted of capital murder during a robbery. At his trial, uncontested expert testimony and other evidence showed that Mr. Lane meets all three criteria: he has an IQ score of 70; he is functionally illiterate, has few academic skills above the third grade level, and was unable to hold a job or conduct simple financial transactions; and his deficits were obvious before age 18.
Despite the fact that the evidence satisfied the professional and legal definitions of intellectual disability established by the Supreme Court, the trial judge sentenced Mr. Lane to death.
EJI attorneys appealed and argued that it was cruel and unconstitutional to sentence Mr. Lane to death in light of his intellectual disability. Even though the expert testimony was uncontested and even though the evidence satisfied the Supreme Court’s definition of intellectual disability, the Alabama Court of Criminal Appeals rejected the arguments about Mr. Lane’s disability and found that his death sentence was appropriate. The Alabama Supreme Court also rejected arguments that Mr. Lane’s death sentence was unconstitutional.
EJI then appealed to the United States Supreme Court and argued that the Alabama courts did not consider the proper professional and legal definitions of intellectual disability in Mr. Lane’s case. As the Supreme Court has stated, “If the States were to have complete autonomy to define intellectual disability as they wished, . . . the Eighth Amendment’s protection of human dignity would not become a reality.”
On Monday, the Supreme Court agreed with EJI, reversed the state court decisions, and ordered the state court to reconsider evidence about Mr. Lane’s intellectual disability in light of the proper professional and legal definitions.