 At trial, the jury heard that Noel had likely suffered "minimal" brain damage.Medical evidence showing the possibility that he suffers from severe brain abnormalities, were discussed in his appeals and clemency petition.However on March 6, 2003, in Noel v State the United States District Court for the Eastern District of Arkansas, ruled that Noel scientific evidence was not substantially better than the evidence of brain abnormality that he produced at the sentencing phase of his trial, and that even if Mr. Noel currently had substantial evidence that he had a brain abnormality, his claim would necessarily fail whatever the nature of that abnormality."