“Mentally retarded persons . . . are individuals whose abilities and behavioral deficits can vary greatly depending on the degree of their retardation, their life experience, and the ameliorative effects of education and habilitation.” So spoke the Supreme Court in upholding the death penalty for individuals who share the single commonality of a low IQ. Yet, despite this recognition by our country’s highest court, that the term “mentally retarded” does not define a distinct class, states continue to view intellectually disabled people as a homogenous group for the purpose of terminating parental rights. They are, in fact, a group of people whose abilities may differ widely, especially in the area of parental abilities.