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discussed above. Id. at 616–21. The district court had “concluded that only the

lowest ends of the IQ ranges ‘had any statistical significance,’ and the other evidence
indicated ‘intelligence that ... was not so subaverage as to meet the standard for [an

intellectual disability.’” Id. at 616–17. The Eighth Circuit affirmed this approach: “[w]

here ‘the lower end of [a defendant’s] score range falls at or below 70,’ courts must

‘move on to consider ... adaptive functioning.’” Id. at 619 (quoting Moore, 581 U.S. at
14). Here, “[t]he lowest end of [the defendant’s] lower IQ score range was 70, so the

district court did not err by considering additional indicia of intellectual disability.”

Id.

See also, e.g., Jackson v. Payne, 9 F.4th 646, 653 (8th Cir. 2021) (“When the low
end of an IQ score range falls at or below 70, courts must move on to consider

the petitioner’s adaptive functioning.”) (cleaned up).

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