Tennessee court rules more than IQ test needed in death row cases
IQ test results are no longer enough to determine whether a convicted felon is fit for the death penalty, ruled the Tennessee Supreme Court Monday.
Tennessee law precludes executing people who are intellectually disabled, and, thanks to Monday’s ruling, an IQ a score of 70 or below is no longer a stand-alone indicator. Now mental health expert testimony will be considered in the ruling.
According to the Memphis Daily News, the decision is based on the appeal of death row inmate Michael Angelo Coleman (PDF), who was convicted for robbing and murdering Leon Watson in Memphis in 1979. Coleman was convicted of six prior violent felonies, and though he met the IQ standard for imposing the death penalty, two experts testified he was intellectually disabled, according to the appeal.
“While a person’s I.Q. is customarily obtained using standardized intelligence tests … the statute does not provide clear direction regarding how a person’s I.Q. should be determined and does not specify any particular test or testing method that should be used,” Justice William C. Koch, Jr. wrote for the Supreme Court. “Ascertaining a person’s IQ is not a matter within the common knowledge of laypersons. Expert testimony in some form will generally be required to assist the trial court in determining whether a criminal defendant is a person with intellectual disability.”
The court found that in Coleman’s case, the lower courts incorrectly treated his intellectual disability and mental illness as two separate causes of his adaptive limitations.