Where a petitioner establishes uncontested proof that despite effort he never progressed beyond the first grade level and dropped out of third grade at age fourteen after social promotion; that he never could understand value of denominations of currency or coins and co uld only make a purchase by holding out his hand with money in it letting the seller take out the amount due; that he did not understand the notion of prices, that is, that two toothbrushes or two loaves of bread or two pencils could cost different am ounts; that he could not read a calendar and could not keep up with dates, even hi s own birthday; that he could not find his way to a new location even in the area where he lived with verbal directions – yet he also could not read written instructio ns; that he would often enter the wrong bathroom, because he was unable to read th e signage or to remember the pictorial symbols for male and female; that to call a friend, he had to use a list which had only phone numbers, not names, and dialed each number in his list one by one until he reached the right person – though often he forgot who he intended to call before he got to that number; that though he held various low-skill jobs, his co-workers had to repeatedly instruct and monitor hi m, even with respect to simple tasks and he lost jobs due to inability to keep himsel f safe on the worksite; that his reported, unadjusted IQ score is between 69 and 72, th at his disabilities existed prior to his eighteenth birthday, and where this Court declared in Moore v. Texas , "States may not execute anyone in 'the entire category of [intellectually disabled] offenders'" may a state thwart the Constitutional prohibition against execution of the intellectually disabled by failing to provide a procedur al vehicle for the adjudication of an Atkins exemption claim? Moore v. Texas , 137 S.Ct. 1039, 1051 (2017) (emphasis in original) (quoting Roper v. Simmons , 543 U.S. 551, 563-63 (2005)).

Whether a state may thwart the constitutional prohibition against execution of the intellectually disabled by failing to provide a procedural vehicle for the adjudication of an Atkins-exemption claim