Moore v. Texas
The Facts
Bobby James Moore shot and killed a grocery store clerk during a robbery in Houston in 1980. He was sentenced to death. Moore sought habeas relief arguing he was intellectually disabled under Atkins v. Virginia. The Texas Court of Criminal Appeals denied his claim, applying a set of informal factors drawn partly from the character Lennie in John Steinbeck's Of Mice and Men. These "Briseño factors" asked whether the defendant could lie effectively, whether they could hide facts or manipulate others, and whether community members thought they were intellectually disabled.
The Conclusion
**The Supreme Court held 5-3 that Texas's framework for assessing intellectual disability in capital cases violated the Eighth Amendment.** States must use current medical standards, not outdated clinical criteria or non-clinical factors like those Texas had employed.
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Case Analysis
Overview
The Supreme Court held 5-3 in 2017 that Texas's framework for determining intellectual disability in capital cases violated the Eighth Amendment. Texas had used outdated clinical standards and relied on a non-clinical set of factors known as the Briseño factors, based partly on the character Lennie from Of Mice and Men. The Court held that states must use current medical standards in assessing intellectual disability, not standards that have been superseded by the medical community.
Conclusion
**The Supreme Court held 5-3 that Texas's framework for assessing intellectual disability in capital cases violated the Eighth Amendment.** States must use current medical standards, not outdated clinical criteria or non-clinical factors like those Texas had employed.
Notes
581 U.S. 1 (2017). Struck down Texas Briseño factors for ID assessment. See Moore v. Texas II (18-443, 2019).
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