Does the Alabama Supreme Court's continued reliance upon evidence that fails to adhere to current medical standards in rejecting Mr. Carroll's claim of intellectual disability violate the Eighth Amendment as set forth in Moore, Brumfield, Hall, and Atkins?

QUESTION PRESENTED Taurus Carroll is intellectually disabled and therefore ineligible for execution pursuant to Atkins v. Virginia, 536 U.S. 304 (2002). At his Atkins hearing in 2012, the trial court disregarded undisputed evidence that he has an IQ of 71 and subaverage intellectual functioning, and used evidence that failed to adhere to current medical standards to discount clinically-valid evidence of significant adaptive deficits. The Alabama appellate courts accepted the evidence that did not adhere to current medical standards, deferred to the trial court, and affirmed Mr. Carroll’s death sentence. Subsequently, this Court granted certiorari and remanded Mr. Carroll’s case to the Alabama appellate courts to reevaluate the evidence in light of Moore v. Texas, 137 S. Ct. 1039 (2017). Despite this Court’s clear directive, on remand, the Alabama appellate courts again deferred to the trial court’s findings, which ignored current medical standards and were made prior to this Court’s decisions in Moore, Brumfield v. Cain, 135 S. Ct. 2269 (2015), and Hall v. Florida, 572 U.S. 701 (2014), raising the following question: Does the Alabama Supreme Court’s continued reliance upon evidence that fails to adhere to current medical standards in rejecting Mr. Carroll’s claim of intellectual disability violate the Eighth Amendment as set forth in Moore, Brumfield, Hall, and Atkins? i