Moore v. Texas (II)
Overview
Overview
The Supreme Court reversed and remanded Bobby James Moore's death sentence for the second time, holding that the Texas Court of Criminal Appeals had again applied an unconstitutional framework for assessing intellectual disability under Atkins v. Virginia, using factors tied to stereotypical depictions of intellectual disability rather than established medical standards.
The Facts
Facts
Bobby Moore was convicted of murder in 1980 during a robbery. He claimed intellectual disability, which bars execution under Atkins v. Virginia. The Texas Court of Criminal Appeals denied his claim using its own Briseño factors, which the Supreme Court had previously found unconstitutional in Moore v. Texas I (2017). On remand, the CCA again denied relief.
The Issue
Issue
Whether Texas applied constitutional standards for determining intellectual disability under Atkins v. Virginia in assessing Bobby Moore's claim, or whether the state again relied on unconstitutional factors.
The Rules
Rule
The Eighth Amendment bars execution of intellectually disabled individuals; states must assess intellectual disability using current clinical standards, not lay stereotypes or factors inconsistent with medical consensus on deficits in adaptive functioning.
The Application
Analysis
Despite the Supreme Court's explicit rejection of the Briseño factors in Moore I, Texas applied those same factors again on remand, emphasizing lay stereotypes of intellectual disability rather than clinical measures of adaptive functioning deficits established in the medical field. The Court found that Texas had persisted in its unconstitutional approach, demonstrating that the state's framework was designed to narrow rather than accurately assess intellectual disability claims under Atkins. Because Moore's record supported findings of intellectual disability under the proper clinical standards, independent of the Briseño framework, the state's continued reliance on constitutionally flawed factors required reversal and remand to ensure a constitutionally compliant determination.
The Conclusion
Conclusion
Court reversed 5-3 and remanded. Texas had continued to use flawed factors. Moore was subsequently resentenced to life in prison.
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