Judge Finds Ronell Wilson Has Intellectual Disability, Removes His Federal Death Sentence

United States District Court Judge Nicholas Garaufis (pic­tured) ruled on March 15 that fed­er­al death row inmate Ronell Wilson is inel­i­gi­ble for the death penal­ty because he has intel­lec­tu­al dis­abil­i­ty. In 2002, the U.S. Supreme Court held in Atkins v. Virginia that the death penal­ty con­sti­tut­ed cru­el and unusu­al pun­ish­ment when applied to peo­ple diag­nosed with intel­lec­tu­al dis­abil­i­ty, then known as men­tal retar­da­tion. Wilson was first sen­tenced to death in New York fed­er­al dis­trict court in 2007, but his death sen­tence was over­turned because of pros­e­cu­to­r­i­al mis­con­duct. Before his sec­ond sen­tenc­ing pro­ceed­ing in 2013, Wilson’s lawyers argued that he had an intel­lec­tu­al dis­abil­i­ty that made him inel­i­gi­ble for the death penal­ty. The dis­trict court reject­ed that claim on the grounds that Wilson’s IQ scores ​“indi­cat­ed suf­fi­cient intel­lec­tu­al func­tion­ing,” and Wilson received a sec­ond death sen­tence. In light of the U.S. Supreme Court’s 2014 deci­sion in Hall v. Florida, the U.S. Court of Appeals for the Second Circuit ordered the dis­trict court to recon­sid­er Wilson’s intel­lec­tu­al dis­abil­i­ty claim. Hall held that apply­ing a bright-line IQ score to reject a claim of intel­lec­tu­al dis­abil­i­ty was incon­sis­tent with accept­ed stan­dards for diag­nos­ing intel­lec­tu­al dis­abil­i­ty and vio­lat­ed the 8^th Amendment. The Court said, ​“When a defen­dan­t’s IQ test score falls with­in the test’s acknowl­edged and inher­ent mar­gin of error, the defen­dant must be able to present addi­tion­al evi­dence of intel­lec­tu­al dis­abil­i­ty, includ­ing tes­ti­mo­ny regard­ing adap­tive deficits.” Applying the appro­pri­ate diag­nos­tic cri­te­ria, Judge Garaufis found that ​“Wilson has demon­strat­ed sig­nif­i­cant deficits in adap­tive func­tion­ing, and he there­fore meets the legal stan­dard for prov­ing intel­lec­tu­al dis­abil­i­ty. Accordingly, Wilson is inel­i­gi­ble to receive the death sen­tence that has been imposed on him.” [UPDATE: On June 26, 2017, fed­er­al pros­e­cu­tors announced that they would not appeal the rul­ing declar­ing Ronell Wilson inel­i­gi­ble for the death penalty.]

(A. Feuer, ​“Ronell Wilson, Killer of 2 Detectives, Will Not Face Death Penalty,” The New York Times, March 15, 2016.) Read the deci­sion here. See Intellectual Disability.