Shoop v. Hill, 586 U.S. ___ (2019)
The Sixth Circuit held that Hill, who was sentenced to death in 1986, was entitled to habeas relief under 28 U.S.C. 2254(d)(1) because the decisions of the Ohio courts concluding that he is not intellectually disabled were contrary to clearly established Supreme Court precedent. The court relied on the 2017 Supreme Court decision, Moore v. Texas. The Supreme Court vacated and remanded so that Hill’s intellectual disability claim can be evaluated based solely on holdings that were clearly established at the relevant time. The Court rejected the Sixth Circuit reasoning “that Moore’s holding regarding adaptive strengths [was] merely an application of what was clearly established by” the Court’s 2002 decision, Atkins v. Virginia. In 2008, when the Ohio Court of Appeals rejected Hill’s claim, Atkins had not provided any comprehensive definition of “mental retardation” for Eighth Amendment purposes. While Atkins noted that standard definitions of mental retardation included as a necessary element “significant limitations in adaptive skills . . . that became manifest before age 18,” Atkins did not definitively resolve how that element was to be evaluated but instead left its application in the first instance to the states. The Moore majority primarily relied on medical literature that postdated the Ohio courts’ decisions.
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