Moore v. Texas

Bobby James Moore was sentenced to death for the 1980 murder of store clerk James McCarble during a robbery in Houston, Texas. Moore claimed he was intellectually disabled and thus ineligible for execution under Atkins v. Virginia. The Texas Court of Criminal Appeals applied the non-clinical Briseno factors, which relied on outdated stereotypes and lay perceptions, and concluded Moore did not have an intellectual disability. Moore appealed to the U.S. Supreme Court, arguing that Texas's standard violated the Eighth Amendment. On March 28, 2017, the Court held that the Texas standard was unconstitutional, as it deviated from current medical consensus and clinical diagnostic frameworks, creating an unacceptable risk that individuals with intellectual disability would be executed.

The U.S. Supreme Court vacated the Texas Court of Criminal Appeals' judgment in a 5-3 decision, holding that the Briseno factors were unconstitutional. The Court ruled that state standards for determining intellectual disability must be informed by the medical community's current diagnostic framework.

Whether Texas' use of the Briseno factors to assess intellectual disability in death penalty cases contravenes the Eighth Amendment and the Supreme Court's precedent in Atkins v. Virginia by ignoring established medical standards and clinical definitions.

The decision reinforced the constitutional prohibition on executing individuals with intellectual disabilities. It required states to adopt clinically informed criteria, reducing arbitrary executions and prompting reforms in death penalty jurisprudence nationwide. The case was widely cited as a critical step in aligning criminal justice with scientific and medical consensus.