Intellectual disability determination and the death penalty

Habeas corpus relief granted to criminal defendant sentenced to death in state court system on grounds that he is ineligible for death penalty due to intellectual disability

Pruitt v. Neal, 788 F.3d 248 (7th Cir. 2015)

Tommy Pruitt was charged with murder, attempted murder, and related offenses in Indiana state court, and was convicted and sentenced to death. After exhausting his state post-conviction remedies, Pruitt sought federal habeas relief claiming that he was intellectually disabled and thus categorically ineligible for the death penalty. He also included several claims alleging ineffective assistance of his trial counsel, including one based on their failure to investigate and present evidence at sentencing that Pruitt suffered from schizophrenia. 

The Seventh Circuit held that the Indiana Supreme Court’s “determination that Pruitt failed to demonstrate significantly subaverage intellectual functioning based on inconsistent test scores” was objectively unreasonable and contrary to the clear and convincing weight of evidence. The Indiana Supreme Court erred by relying on “inaccurate assumptions and select pieces of evidence” in its factual determination, weighing circumstantial evidence—such as Pruitt’s ability to fill out applications for employment and his other work and school history—as more indicative of his true intellectual ability than his many subaverage IQ test scores. The Court also noted that the state court record contained “unrebutted evidence that Pruitt satisfie[d] the adaptive behavior prong of intellectual disability.” The Seventh Circuit also held that trial counsel’s failure to investigate and present evidence of Pruitt’s paranoid schizophrenia was “sufficiently egregious and prejudicial” to establish ineffective assistance. Ultimately, the Seventh Circuit reversed the judgment of the district court and remanded the case for new penalty-phase proceedings.

Found in DMHL Volume 34 Issue 2