Texas death row inmate Jose Garcia Briseño, whose case was used by the Texas courts to establish a very restrictive definition of mental retardation, has been resentenced to life without parole. His sentence was the result of a plea bargain ending years of litigation. Briseño has been on death row for over 20 years, and received a stay of execution in 2009 just 5 days before he was to be executed. Briseño's lawyers have argued he is intellectually disabled, and therefore ineligible for the death penalty, but a Texas court said his crime required forethought, planning, and complex execution, so he was not mentally retarded. No other state uses such non-scientific factors in determining intellectual disability. Recently, the American Association on Intellectual and Developmental Disabilities criticized the use of these "Briseño factors" in a brief to the U.S. Supreme Court: “[The Texas] impressionistic ‘test’ directs fact-finders to use ‘factors’ that are based on false stereotypes about mental retardation that effectively exclude all but the most severely incapacitated.” (Chester v. Thaler 2012). Staff from the Texas Department of Criminal Justice had earlier intervened on Briseño's behalf because he had been so helpful to other inmates.