Pruitt v. Neal

Dist. Ct. erred in denying defendant’s habeas petition challenging his death penalty on grounds that defendant was intellectually disabled, and thus was constitutionally ineligible for death penalty. While record showed that some of defendant’s IQ scores were inconsistent with finding that defendant had significantly subaverage intellectual functioning, reliable IQ test scores were consistently within range of significantly subaverage intellectual functioning category. Moreover, defendant presented extensive evidence that his adaptive functioning skills were significantly impaired to that of six-to-eight year olds in all areas. Defendant’s counsel was also ineffective in failing to fully investigate and present evidence at sentencing hearing that defendant suffered from paranoid schizophrenia, especially where trial counsel had argued that death sentence was unwarranted, in part, because defendant suffered from serious mental illness.