into account the most recent medical guide on intellectual disabilities. "A diagnosis of intellectual disability requires three things: 1) significantly subaverarge intellectual functioning (typically measured by an IQ score roughly two standard deviations below the mean); 2) adaptive-functioning deficits; and 3) an onset during childhood, before reaching 18. As the court recognized in Hall v. Florida (2014), intellectual disability is a condition, not an IQ score, and proper diagnosis thus places great emphasis on the second requirement, related to adaptive functioning." The Court further decided that instead of stereotypes, science should govern death penalty cases involving intellectually-disabled prisoners and that courts should base their decisions on opinions of professional organizations like the American Psychological Association. Subsequent developments for Daryl Atkins A jury in Virginia decided in July 2005 that Atkins was intelligent enough to be executed on the basis that the constant contact he had with his lawyers provided intellectual stimulation and raised his IQ above 70, making him competent to be put to death under Virginia law. The prosecution had argued that his poor school performance was caused by his use of alcohol and drugs, and that his lower scores in earlier IQ tests were tainted. In January 2008, Circuit Court Judge Prentis Smiley, who was revisiting the matter of whether Atkins was mentally disabled, received allegations of prosecutorial misconduct. These allegations, if true, would have authorized a new trial for Atkins. After two days of testimony on the matter, Smiley determined that prosecutorial misconduct had occurred. At this juncture, Smiley could have vacated Atkins's conviction and ordered a new trial. Instead, Smiley determined the evidence was overwhelming that Atkins had participated in a felony murder and commuted Atkins's sentence to life in prison. Prosecutors sought writs of mandamus and prohibition in the Virginia Supreme Court on the matter, claiming Smiley had exceeded his judicial authority with his ruling. On June 4, 2009, the Virginia Supreme Court, in a 5-2 decision authored by Chief Justice Leroy R. Hassell Sr., ruled that neither mandamus nor prohibition was available to overturn the court's decision to commute the sentence. Justice Cynthia D. Kinser, joined by Justice Donald W. Lemons, considered the two most conservative justices of the Court, wrote a lengthy dissent that was highly critical of both the majority's reasoning and the action of the circuit court in commuting the sentence. See also List of United States Supreme Court decisions on