Jamaal Howard v. Texas

In Atkins v. Virginia, Hall v. Florida, and Moore v. Texas, this Court held that a State’s determination of whether a prisoner is intellectually disabled must be informed by the medical community’s current diagnostic framework. The current framework no longer requires—as it once did—that person’s adaptive deficits be “directly related” to his intellectual impairment; in addition, the current framework now recognizes that the developmental period extends to age 22. These two significant changes to the diagnostic criteria for assessing intellectual disability lead to the following question: When an inmate’s Atkins claim was rejected under obsolete diagnostic criteria but the inmate returns to the state court with evidence demonstrating he satisfies the existing criteria, do this Court’s precedents or the Eighth Amendment require that the inmate’s claim of intellectual disability be newly assessed in light of currently prevailing clinical standards?