Whether the Eighth Amendment categorically bars the execution of an intellectually disabled defendant whose IQ scores and adaptive deficits demonstrate intellectual disability

and that Mr. Pye will ultimately prevail on the merits of his underlying Eighth and Fourteenth Amendment Claims. First, Mr. Pye is intellectually disabled. This is a categorical ban to execution. All experts agree that his IQ scores place him in the range of the intellectually disabled. Testing by experts for both the state and the defense show that he has significant adaptive deficits. This Court has held that the execution of an intellectually disabled individual violates the Eighth Amendment. Mr. Pye is likely to succeed on the merits. Mr. Pye and all those on death row retain a fundamental right to life under the Fourteenth Amendment to the United States Constitution. See Ohio Adult Parole Auth. v. Woodard, 523 U.S. 272