What Makes a Defendant Intellectually Disabled? United States Supreme Court May Decide.

The Eighth Amendment of the constitution prohibits cruel and unusual punishment. A punishment is considered cruel and unusual for many reasons, one of which is if the punishment is grossly disproportionate to the crime committed. In general, sentencing an intellectually disabled person to death is considered cruel and unusual punishment. The standard for providing an intellectual disability may soon change if the United States Supreme Court grants cert to the case of Commonwealth v. Knight. 

What happened in the Knight case? 

Over the course of four days in February of 2010, the defendant, along with five codefendants, allegedly kidnapped, tortured, and murdered Jennifer Daugherty, a 30-year-old woman with an intellectual disability. She was determined to have the intellectual capacity of a 14-year-old. The victim was staying at an apartment with another codefendant before going to her doctor’s appointment. She angered the host of the apartment by attempting to have sex with him. The girlfriend of the apartment owner became angry and began assaulting the victim by hitting her in the chest and head. She then poured water, spices, and oatmeal on her before removing the victim’s clothing and cutting her hair. When the victim attempted to leave the home, the defendant and other codefendants came to the home and beat the victim. The next day, the torture escalated. The victim was forced to drink urine and feces, powdered detergent, and prescription medication. The defendant raped the victim. She was bound and gagged and had her face painted. Finally, the defendant and codefendants forced the victim to write a suicide note and then killed her by stabbing her in the chest, neck, wrists and choking her. 

When the defendant was charged with first-degree murder, he offered expert testimony from a clinical psychologist and a clinical neuropsychologist regarding his IQ scores and limitations to adaptive function. However, the clinical psychologist’s testimony failed to establish that the defendant suffered from an intellectual disability for many reasons: the defendant took multiple IQ tests scoring between 77-97. While the defendant’s IQ scores are low, they are not low enough to be considered disabled, which is in the 65-75 range. The defendant’s assessment only satisfied one of the criteria for one of the three legs of intellectual disability. Due to this finding, the court declined to offer an instruction to the jury regarding the defendant’s mental disability. 

In Pennsylvania, courts use a three-part test to determine if a defendant is mentally disabled. Courts look to limited intellectual function, significant adaptive limitation, and onset prior to age 18. The defendant only satisfied one of these requirements, and there was no previous documented evidence of a mental disability. 

The defendant argued that it is the jury who should make this determination, not the judge. The defendant petitioned the United States Supreme Court to challenge Philadelphia’s rigid rules for proving an intellectual disability.

If the United States Supreme Court takes this case, it could drastically change death penalty procedure. For more information on important Supreme Court Cases, follow Attorney DelSignore on Facebook.