Whether the TCCA contravened the Eighth and Fourteenth Amendments, and this Court's precedents, when it evaluated petitioner's intellectual-disability claim based on its own standard instead of medically-accepted criteria

QUESTIONS PRESENTED Petitioner James Harris Jr. has an IQ in the bottom 5th percentile and has trouble with basic everyday tasks like reading, arithmetic, and living independently. Those facts should have prompted a robust investigation into intellectual disability in preparation for the mitigation phase of Mr. Harris’s capital murder trial. Instead, Mr. Harris’s lawyer never hired anyone to evaluate Mr. Harris for an intellectual disability and disclaimed any argument that Mr. Harris was intellectually disabled. The jury recommended that he be sentenced to death. When Mr. Harris was finally evaluated by a qualified doctor, he was diagnosed with an intellectual disability that renders him ineligible for the death penalty. The state habeas trial court and the Texas Court of Criminal Appeals (TCCA) rejected Mr. Harris’s intellectual disability claim based on an analysis that departs from the medically accepted standard. This Court has already twice corrected the same error. See Moore v. Texas (“Moore I’), 137 8. Ct. 1039 (2017); Moore v. Texas (“Moore IT’), 139 8. Ct. 666 (2019). The TCCA also rejected the state habeas trial court’s detailed factfindings and legal conclusions that Mr. Harris received ineffective assistance of counsel from a lawyer who inadequately pursued the possibility of Mr. Harris’s intellectual disability. The questions presented are: 1. Whether the TCCA contravened the Eighth and Fourteenth Amendments, and this Court’s precedents, when it evaluated petitioner’s intellectual disability ii claim based on its own standard instead of medically accepted criteria. 2. Whether petitioner received ineffective assistance of counsel in violation of the Sixth Amendment when his counsel abandoned an investigation into his intellectual disability without having any medical professional evaluate the defendant for that condition. iii STATEMENT OF