Challenge to the Death Penalty

Facts of the Case

In September 1985, Raymond Fife, a 12-year-old boy, left home on his bicycle to visit a friend. When Raymond did not return home, his parents began a search, and his father eventually found him naked, beaten, and burned in a wooded field. Although he was hospitalized, Raymond died from his injuries two days later. Subsequently, Danny Hill, age 18, appeared at a local police department and inquired about a reward for information regarding the crime. Police determined that Mr. Hill knew more information than was publicly available. Eventually, Mr. Hill admitted to his involvement in the murder.

In 1986, Mr. Hill was convicted. The court opinion from the Sixth Circuit, Hill v. Anderson, 300 F.3d 679 (6th Cir. 2002), summarizes his sentencing, which reveals that a mitigation hearing was held to determine whether he would receive the death penalty. During the mitigation hearing, three psychologists testified that Mr. Hill was intellectually disabled. The aggravating circumstances outweighed Mr. Hill's mitigating factors, and he was sentenced to death.

An intermediate appellate court and the Ohio Supreme Court affirmed his conviction and sentence, and the U.S. Supreme Court denied certiorari in 1993. After unsuccessful petitions to state and federal courts for postconviction relief, he petitioned the Ohio courts arguing that under Atkins v. Virginia, 536 U.S. 304 (2002), his death sentence should be invalidated. In 2006, the Ohio trial court found that Mr. Hill was not intellectually disabled due to his adaptive strengths and denied Mr. Hill's claim. In 2008, the Ohio Court of Appeals affirmed the denial, and in 2009, the Ohio Supreme Court denied review.

In 2010, Mr. Hill filed a new federal habeas petition under 28 U.S.C. § 2254 (1996), seeking review of the Ohio courts' denial of his Atkins claim. Following a denial by the district court, the Sixth Circuit Court of Appeals reversed and granted habeas relief under § 2254(d)(1), which applies to a state court's decision that was contrary to, or was an unreasonable application of, clearly established federal law at the time of the decision. In granting habeas relief, the Sixth Circuit stated that the Ohio courts erred by relying too heavily on Mr. Hill's adaptive strengths in the controlled environment of a death-row prison cell. In reaching its ruling, the court relied on the U.S. Supreme Court's decision in Moore v. Texas, 137 S.Ct. 1039 (2017). Moore held that a Texas appellate court improperly evaluated a petitioner's adaptive functioning by overemphasizing his perceived adaptive strengths and by overly focusing on the petitioner's improved behavior in prison, despite the medical community's expressed caution about relying on adaptive strengths developed in controlled environments.

While the Sixth Circuit acknowledged that the 2017 Moore decision postdated the Ohio courts' denials of Mr. Hill's Atkins claim, that court reasoned that the Moore decision regarding adaptive strengths was essentially an application of federal law already established in Atkins. The state appealed and argued that the Sixth Circuit's decision violated § 2254(d)(1) because it relied on Moore, which was decided years after the Ohio courts' decisions and did not represent clearly established federal law within the relevant timeframe. In response, Mr. Hill argued that Moore simply elucidated the law clearly established in Atkins in relation to the assessment of adaptive skills.

Ruling and Reasoning

The U.S. Supreme Court ruled that the Sixth Circuit improperly relied on its 2017 decision in Moore in granting Mr. Hill's habeas relief claim under § 2254(d)(1). Consequently, the circuit court's judgment was vacated and remanded for further proceedings. In reaching its conclusion, the U.S. Supreme Court pointed out that federal habeas relief under 28 U.S.C. § 2254(d)(1) may only be granted if a state court reached a decision that was contrary to, or involved an unreasonable application of, Supreme Court precedent that was clearly established at the time of the decision. Accordingly, the Court focused on clearly established precedent at the time of the Ohio Court of Appeals' denial of Mr. Hill's Atkins claim in 2008.

The Court pointed out that, while the Atkins ruling in 2002 prohibited death sentences for individuals with an intellectual disability, it did not establish a definition of intellectual disability for constitutional analysis. The Court explained that the Atkins opinion merely noted that the definitions utilized by the American Association on Mental Retardation and the American Psychiatric Association required subaverage intellectual functioning and significant limitations in adaptive skills before age 18. Further, the Court noted that state statutory definitions regarding intellectual disability that were established at the time generally conformed to those clinical definitions. The Court tasked state jurisdictions with developing appropriate methods to comply with the Atkins ruling.

The Court emphasized that, more than a decade after Atkins, it had expounded on the definition of intellectual disability in Hall v. Florida, 572 U.S. 701 (2014) and in Moore. In Hall, the Court rejected a rule restricting Atkins relief to defendants with an IQ test score of 70 or less because it prevented consideration of other evidence of intellectual disability, including adaptive deficits. In Moore, the Court found that the Texas Court of Criminal Appeals improperly evaluated a petitioner's adaptive functioning and erred in concluding that a petitioner's IQ scores, some of which were below 70, established that he was not intellectually disabled.

In this case, the Court rejected the Sixth Circuit's reasoning that Moore was merely an application of what had already been clearly established by Atkins, as Atkins did not provide a definition for intellectual disability and only briefly commented on definitions by professional clinical organizations. The Court further noted that Atkins did not resolve how limitations in adaptive skills were to be assessed, and it deferred that task to state jurisdictions. Finally, the Court highlighted that Moore primarily relied on medical literature that postdated the Ohio courts' decisions on Mr. Hill's Atkins claim. As a result, the Court vacated and remanded due to the lower court's heavy and improper reliance on Moore. The case was remanded so that Mr. Hill's intellectual disability could be assessed in light of court holdings established at the relevant time.