Russell Holden and Roderick Rankin were sentenced to death for committing heinous crimes of rape and murder. Each man insisted that he was mentally retarded and asked that his life be spared. Mr. Holden was convicted of attempted rape and first degree murder of a woman acquaintance. The victim was found with a gunshot wound to her neck and a slashed throat. The evening before the murder, Mr. Holden and a companion agreed to give a ride home to a friend and a young woman. He refused to stop the car at the woman's home. When he dropped her male companion off, the woman remained in the back of the car. He told the companion that he "was going to get some meat" and "[w]ould probably have to kill the victim] so she won't tell anybody."

He was apprehended and charged with three counts of capital murder. He presented evidence of his retardation and organic brain damage to a North Carolina jury, which nonetheless convicted and sentenced him to death.

The defendants appealed their death sentences to the Supreme Court of their respective states. Mr. Rankin argued that his test results established a rebuttable presumption of mental retardation and the trial judge erred by refusing to find that he was mentally retarded at the time the murders were committed. Mr. Holden argued that sentencing a mentally retarded person to death violated state and federal constitutional protections against cruel and unusual punishment.

Holding: The North Carolina Supreme Court affirmed that the state constitution does not prohibit the execution of mentally retarded persons. The sentencer can consider mitigating evidence of mental retardation when imposing the death penalty, but whether or not death is the appropriate punishment is a determination that is individual to each case. Mr. Holden's jury was permitted to consider evidence of his disabilities. The Court held intact the jury's decision that Mr. Holden's documentation failed to mitigate his death sentence.

The Arkansas Supreme Court established a standard for reviewing a trial court's ruling on the question of mental retardation. The Court held that the ruling would be upheld if it was supported by substantial evidence. In Mr. Rankin's case, the results of his IQ testing more accurately classified him as "borderline intelligent". His death sentence was upheld.