Hill v. Anderson, No. 14-3718 (6th Cir. 2018)Annotate this Case
Hill’s death penalty sentence was imposed in 1986. Hill brought a habeas petition, arguing that he may not be executed because he is “intellectually disabled,” as defined in subsequent Supreme Court cases. In 2002 the Sixth Circuit remanded for consideration of the Supreme Court’s opinions on the subject. The Sixth Circuit subsequently concluded that the Ohio courts unreasonably applied the Supreme Court’s three-part standard, which requires three separate findings for a diagnosis of intellectual disability: the individual exhibits significant deficits in intellectual functioning—indicated by an IQ score “approximately two standard deviations or more below the mean,” roughly 70; the individual exhibits significant adaptive skill deficits—such as “the inability to learn basic skills and adjust behavior to changing circumstances” in specified skill sets; and the deficits arose while the individual was still a minor. Hill’s IQ ranges from 48 to 71; his disability was documented before he reached age 18. Ohio courts gave undue weight to Hill’s behavior in prison. Hill was universally considered to be intellectually disabled by teachers, administrators, and the juvenile court system. Hill consistently performed very poorly in school; there was consistent documentation that he had trouble maintaining proper hygiene despite reminders; he had trouble making friends and responding appropriately to authority figures; he was described as vulnerable to exploitation.