After being convicted by Ohio’s state courts for murder and sentenced to death in 1986, Danny Hill challenged the judgment on the basis that the Eighth Amendment prohibits someone who is “mentally retarded” from receiving a death sentence, as established in Atkins v. Virginia, 536 U.S. 304 (2002). When that failed in the state courts, he filed a federal habeas petition seeking review. The district court denied his petition, but the Sixth Circuit reversed, holding that the U.S. Supreme Court’s ruling in Moore v. Texas, 581 U.S. ___ (2017) governed the standard the Ohio courts should have used for determining whether Hill was mentally retarded and thus immune from the death penalty. In a per curiam decision with no dissents, the U.S. Supreme Court reversed, holding that the Sixth Circuit’s reliance on Moore was misplaced. Under the Antiterrorism and Effective Death Penalty Act of 1996, a federal court can only overturn a state court’s imposition of the death penalty if it “resulted in a decision that was contrary to, or involved an unreasonable application of” SCOTUS precedent that was “clearly established” at the time of the adjudication. Subsequent case law is not considered in that analysis. The Court remanded the case for further consideration solely on the legal standards that were in place at the time of Hill’s denial of relief by Ohio’s state courts. A link to the opinion in Shoop v. Hill is here.