Law360 (August 27, 2026, 3:41 PM EDT) -- A group of young adults who say they have intellectual disabilities alleged in a new lawsuit that Connecticut's "strict intelligence quotient cutoff" for receiving state agency services is unconstitutional and ignores shifts in the medical and legal landscapes.
Four plaintiffs from southern Connecticut, between the ages of 19 and 23, sued the Department of Developmental Services and its commissioner in a complaint made public Tuesday in Hartford Superior Court, seeking an order that the agency must stop denying applications based on IQ scores of 70 or higher. Each plaintiff said DDS rebuffed their requests for services that would support their ability to work or otherwise "participate in community life" because they tested above the cutoff at least once.
"IQ tests do not measure realms of intelligence critical to one's ability to live and work independently as an adult," the complaint said. "Thus, the exclusive use of IQ test results as the measure of one's ability to live and work independently is not rationally related to the government's purpose of providing DDS services."
At issue is Connecticut General Statutes Section 1-1g, which lays out a definition of intellectual disability that the agency uses to determine eligibility. Part of the definition refers to "an intelligence quotient more than two standard deviations below the mean," and DDS' application of the law limits eligibility to those with scores under 70, the plaintiffs said.
The complaint alleged that the cutoff violates the equal protection and due process clauses of the U.S. Constitution, as well Article I Sections 8 and 20 of the Connecticut Constitution. Those state-level provisions respectively bar deprivation of property without due process and require equal protection of the law for those with physical or mental disabilities.
"The most recent edition of the Diagnostic and Statistical Manual of Mental Disorders, the authoritative practitioner's guide for diagnosing intellectual disability, abandons specific IQ scores as a criterion for diagnosis and focuses on adaptative functioning and life skills performance as key indicators of intellectual disability," according to the complaint.
"Medical and psychological professionals consider IQ scores to be just one of several factors to identify intellectual disability," the plaintiffs said.
All four plaintiffs said a clinician found they met the criteria for intellectual disability included in the diagnostic manual, known as the DSM-5.
When Andrew Baylis was 17, his IQ score was measured at 72. Now he is 23 and remains "fully dependent" on his parents for most of his daily living activities like brushing his teeth and putting on his socks, the complaint said.
Still, DDS "denied case management services and other services necessary to allow him to continue to participate in community life, or to pursue employment," according to the complaint.
The other plaintiffs said they had similar histories and needs, and similar experiences with DDS.
"Absent this court's intervention, plaintiffs will continue to be deprived of critical resources and services necessary to their developmental ability to function independently and participate in community life, which will continue to cause immediate and irreparable harm," the complaint said.
The plaintiffs also pointed to the 2014
U.S. Supreme Court opinion in
Hall v. Florida, which rejected "a strict mandatory IQ cutoff" for death penalty decisions. That decision said "an individual's intellectual functioning cannot be reduced to a single numerical score" and the tests have an "acknowledged and inherent margin of error."
Counsel for the plaintiffs did not immediately respond to requests for comment Thursday. A representative of DDS said the department does not comment on pending litigation.
The plaintiffs are represented by Luke Reynolds and Christopher Mattei of
Koskoff Koskoff & Bieder PC, Andrew Alan Feinstein of Feinstein Education Law Group and Sarah Eagan, Jennifer Wheeler and Sarah Mervine of the Center For Children's Advocacy.
Counsel information for the defendants was not immediately available.
The case is Baylis et al. v. Department of Developmental Services et al., case number HHD-CV26-6230263-S, in the Hartford Judicial District of the Connecticut Superior Court.
--Editing by Patrick Reagan.
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