Maryland
How Atkins v. Virginia applies in Maryland: state-specific rules, key cases, and bar exam notes for Constitutional Law (Eighth Amendment; Criminal Procedure/Death Penalty).
Maryland law reflects the principles established in Atkins v. Virginia, prohibiting the execution of intellectually disabled individuals. The Maryland Court of Appeals emphasizes a thorough evaluation of IQ and adaptive functioning to determine intellectual disability.
In Maryland, an individual is exempt from the death penalty if they have an intellectual disability, defined pursuant to the criteria established in Atkins, namely significant limitations in intellectual functioning and adaptive behavior.
The Maryland Court of Appeals affirmed that the defendant was not eligible for the death penalty due to their intellectual disability after comprehensive assessments.
The court ruled that the determination of intellectual disability must include consideration of adaptive functioning as well as IQ scores.
The trial court properly conducted a hearing on the defendant's intellectual disability, in line with the standards set in Atkins.
Maryland’s approach aligns closely with the federal standard articulated in Atkins v. Virginia, emphasizing a comprehensive evaluation of both intellectual capacity and adaptive behavior. However, specific procedural mechanisms in determining intellectual disability may vary, as Maryland provides more detailed criteria in its state court rulings.
Atkins v. Virginia is relevant for the Maryland bar exam, particularly in the context of Eighth Amendment issues in capital cases, emphasizing the distinction between intellectual disability and mental illness.