Williams v. Mitchell, No. 12-4269 (6th Cir. 2015)
Annotate this CaseIn 1989 Williams was convicted of aggravated murder and sentenced to death. After filing direct appeals and seeking post-conviction relief in state and federal courts, Williams filed a post-conviction petition in state court, based on the Supreme Court’s “Atkins” decision, arguing that he is ineligible for the death penalty because he is intellectually disabled. Ohio courts rejected Williams’s petition. The district court denied Williams’s federal habeas petition. The Sixth Circuit vacated and remanded for issuance of a conditional writ, finding the state court’s application of law with regard to whether Williams is intellectually disabled under Atkins was contrary to clearly established Federal law. The court noted refusal to consider past evidence of intellectual disability in determining whether Williams has significantly sub-average mental functioning and adaptive skills limitations. There was no basis for the Ohio Court of Appeals to have assumed, as it apparently did, that most low childhood IQ scores are the result of developmental delays.
The court issued a subsequent related opinion or order on October 28, 2015.
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