The term imbecile was once used by psychiatrists to denote a category of people with moderate to severe intellectual disability, as well as a type of criminal. The word arises from the Latin word imbecillus, meaning weak, or weak-minded. It originally referred to people of the second order in a former and discarded classification of intellectual disability, with a mental age of three to seven years and an IQ of 25–50, above "idiot" and below "moron". In the obsolete medical classification, these people were said to have "moderate mental retardation" or "moderate mental subnormality" with IQ of 35–49, as they are usually capable of some degree of communication, guarding themselves against danger and performing simple mechanical tasks under supervision.
Roper v. Simmons, 543 U.S. 551 (2005), is a landmark decision by the Supreme Court of the United States in which the Court held that it is unconstitutional to impose capital punishment for crimes committed while under the age of 18. The 5–4 decision overruled Stanford v. Kentucky, in which the court had upheld execution of offenders at or above age 16, and overturned statutes in 25 states.
Atkins v. Virginia, 536 U.S. 304 (2002), is a case in which the Supreme Court of the United States ruled 6–3 that executing people with intellectual disabilities violates the Eighth Amendment's ban on cruel and unusual punishments, but that states can define who has an intellectual disability. At the time Atkins was decided, 18 of the 38 death penalty states exempted mentally disabled offenders from the death penalty.
A large body of research indicates that IQ and similar measures vary between individuals and between certain groups, and that they correlate with socially important outcomes such as educational achievement, employment, crime, poverty and socioeconomic status.
Dobie Gillis Williams was an American criminal in Louisiana who was convicted of the murder of Sonja Knippers in 1984, and sentenced to death. He was executed in 1999. His case has been controversial.
Coker v. Georgia, 433 U.S. 584 (1977), held that the death penalty for rape of an adult was grossly disproportionate and excessive punishment, and therefore unconstitutional under the Eighth Amendment to the U.S. Constitution.
Marvin Lee Wilson was executed by the State of Texas on August 7, 2012, despite experts finding his IQ was 61. Supreme Court rulings subsequent to his execution in 2014 and 2017 ruled that the Eighth Amendment protected people with this low of an IQ from being executed under the discretion some states, including Texas, were using at the time. Texas successfully used crime allegation specifics to argue against the expert IQ, but the states are no longer allowed to do that. He entered death row on May 9, 1994, for the murder of a police drug informant who had caught him dealing cocaine. On November 10, 1992, Wilson abducted and shot 21-year-old Jerry Robert Williams following a physical confrontation between the two in the 1500 block of Verone in Beaumont. Wilson then left the body of Williams at a bus stop where it was later found by a bus driver. At the time of the murder, Wilson had two previous convictions for robbery, one of them aggravated.
Wrongful execution is a miscarriage of justice occurring when an innocent person is put to death by capital punishment. Opponents of capital punishment often cite cases of wrongful execution as arguments, while proponents argue that innocence concerns the credibility of the justice system as a whole and does not solely undermine the use of the death penalty.
Johnny Paul Penry is a Texas prisoner serving three consecutive sentences of life imprisonment without parole for rape and murder. He was on death row between 1980 and 2008, and his case generated discussion about the appropriateness of the death penalty for offenders who are thought to be intellectually disabled.
Penry v. Lynaugh, 492 U.S. 302 (1989), was a United States Supreme Court case that sanctioned the death penalty for mentally disabled offenders because the Court determined executing the mentally disabled was not "cruel and unusual punishment" under the Eighth Amendment. However, because Texas law did not allow the jury to give adequate consideration as a mitigating factor to Johnny Paul Penry's intellectual disability at the sentencing phase of his murder trial, the Court remanded the case for further proceedings. Eventually, Penry was retried for capital murder, again sentenced to death, and again the Supreme Court ruled, in Penry v. Johnson, that the jury was not able to adequately consider Penry's intellectual disability as a mitigating factor at the sentencing phase of the trial. Ultimately, Penry was spared the death penalty because of the Supreme Court's ruling in Atkins v. Virginia, which, while not directly overruling the holding in "Penry I", did give considerable negative treatment to Penry on the basis that the Eighth Amendment allowed execution of mentally disabled people.
In the United States criminal justice system, a competency evaluation is an assessment of the ability of a defendant to understand and rationally participate in a court process.
Tennard v. Dretke, 542 U.S. 274 (2004), was a United States Supreme Court case in which the court was asked whether evidence of the defendant's low IQ in a death penalty trial had been adequately presented to the jury for full consideration in the penalty phase of his trial. The Supreme Court held that not considering a defendant's low IQ would breach his Eighth Amendment rights and constitute a cruel and unusual punishment.
Barefoot v. Estelle, 463 U.S. 880 (1983), is a United States Supreme Court case. The Court ruled on the admissibility of clinical opinions given by two psychiatrists hired by the prosecution in answer to hypothetical questions regarding the defendant's future dangerousness and the likelihood that he would present a continuing threat to society in this Texas death penalty case. The American Psychiatric Association submitted an amicus curiae brief in support of the defendant's position that such testimony should be inadmissible and urging curtailment of psychiatric testimony regarding future dangerousness and a prohibition of such testimony based on hypothetical data.
Jeffery Lee "Jeff" Wood is a man on death row in the state of Texas. He was scheduled for execution in 2008 and 2016 before stays of execution were issued. As in the case of Kenneth Foster, Wood's death sentence stems from the Texas law of parties, which is related to the felony murder rule.
Intellectual disability (ID), also known as general learning disability, and formerly mental retardation, is a generalized neurodevelopmental disorder characterized by significant impairment in intellectual and adaptive functioning that is first apparent during childhood. Children with intellectual disabilities typically have an intelligence quotient (IQ) below 70 and deficits in at least two adaptive behaviors that affect everyday living. According to the DSM-5, intellectual functions include reasoning, problem solving, planning, abstract thinking, judgment, academic learning, and learning from experience. Deficits in these functions must be confirmed by clinical evaluation and individualized standard IQ testing. On the other hand, adaptive behaviors include the social, developmental, and practical skills people learn to perform tasks in their everyday lives. Deficits in adaptive functioning often compromises an individual's independence and ability to meet their social responsibility.
James Lee Clark was an American murderer with an intellectual disability whose controversial execution by the state of Texas sparked international outcry. The controversy involved the argument that his execution violated the U.S. Supreme Court ruling in Atkins v. Virginia (2002), which held that executions of intellectually disabled criminals is cruel and unusual punishment, which is prohibited by the Eighth Amendment.
Penry v. Johnson, 532 U.S. 782 (2001), is a United States Supreme Court case which concerned whether instructions given to a Texas jury were constitutionally adequate to emphasize the mitigating factors in sentencing of defendants who are intellectually disabled The Texas courts had determined the sentencing instructions were consistent with prior Supreme Court jurisprudence, but the Court in a divided decision reversed, finding the sentencing instructions insufficient. This was the second time Penry's case made it to the Supreme Court.
Hall v. Florida, 572 U.S. 701 (2014), was a United States Supreme Court case in which the Court held that a bright-line IQ threshold requirement for determining whether someone has an intellectual disability is unconstitutional in deciding whether they are eligible for the death penalty.
Brumfield v. Cain, 576 U.S. 305 (2015), was a United States Supreme Court case in which the Court held that because Brumfield satisfied 28 U.S.C. § 2254(d)(2)’s requirements, he was entitled to have his Atkins v. Virginia claim considered on the merits in federal court.
On July 29, 1997, in Houston, Texas, 48-year-old Nancy Adleman, a mother of three, was abducted and murdered while jogging. Her body was found in a forested area along Brays Bayou the day after she failed to return home. Adleman's murderer, Arthur Lee Burton, was later arrested and charged with her murder. Burton confessed that he had kidnapped and attempted to rape Adleman, ultimately strangling her with her own shoelaces. Although Burton later retracted his confession, claiming he admitted to the crime under duress and had an intellectual disability, he was found guilty of murder and sentenced to death in 1998. Burton was executed at age 54 on August 7, 2024.
