State v. Roque
In State v. Roque, 213 Ariz. 193, 141 P.3d 368 (2006), the defendant who was sentenced to death attempted to argue that he was "mentally retarded and thus not subject to execution." Id. at 227,145, 141 P.3d at 402. Despite his full scale IQ of 80, he argued the court should look to the lowest of his sub-tests to determine that he was mentally retarded. Id. at148.
The court found that he had "misinterpreted the statute" because it "does not refer to individual IQ sub-tests or indices, but rather employs a single intelligence quotient as an initial measure of significantly subaverage general intellectual functioning. This number refers to the full-scale IQ." Id. at 228,150, 141 P.3d at 403. Consequently, the court rejected his argument. Id.