 His defense lawyers argued that, despite tests showing an IQ of 80, Noel had a brain disorder and that executing him would have violated a U.S. Supreme Court directive.The lawyers also argued that medical tests not developed by the time of Noel's 1996 trial might have revealed more about his mental health.It was argued that psychologists and neurologists learned significantly more about Noel's brain damage since his trial, and have established strong connections between his neuropsychological deficit and his aggressive, impulsive behavior.