Is Atkins getting smarter?

This Findlaw article accuses Virginia of evading the Supreme Court's ruling in the Atkins case, as it continues to work towards the execution of Atkins himself. The author asks: "Is Atkins gradually getting smarter? Of course not." The article goes on to conclude that "when prosecutors, and their experts, argue that a death row inmate's reduced cognitive capabilities developed not in early childhood, but much later --- perhaps even in prison - the inmate may not have proof to rebut that contention, even if false."