Rogers v. Chatman

Whether petitioner was denied effective assistance of counsel where (1) the only issue at trial was whether petitioner is intellectually disabled; (2) petitioner"s IQ scores were within the range for intellectual disability with the Flynn effect, a well-established scientific principle demonstrating that aging norms cause IQ scores to rise for each year since the test was normed, but outside the range without it; and (3) petitioner"s counsel failed to explain the Flynn effect.