In Commonwealth v. Cox, the Pennsylvania Supreme Court considered an appeal from the denial of PCRA relief in a capital case. The defendant claimed he was intellectually disabled and could not be executed. The Court focused on whether the defendant had “significant adaptive limitations.” The Court found the PCRA court’s weighing of that factor deficient and remanded for further proceedings. Justice Wecht authored the opinion and deserves credit for providing a thorough and thoughtful overview of the intersection of 8th Amendment jurisprudence and intellectual disabilities.
