Hall v. Florida

Supreme Court of the United States
572 U.S. 701, 188 L. Ed. 2d 1007, 2014 U.S. LEXIS 3615 (2014)

ELI5:

Rule of Law:

Under the Eighth Amendment, a state may not define intellectual disability for purposes of capital punishment with a rigid IQ score cutoff, as such a rule creates an unacceptable risk of executing intellectually disabled individuals by failing to account for the standard error of measurement inherent in IQ testing.

Facts:

On February 21, 1978, Freddie Lee Hall and his accomplice, Mark Ruffin, kidnaped, beat, raped, and murdered Karol Hurst, a pregnant 21-year-old.
Shortly thereafter, Hall and Ruffin drove to a convenience store where they killed Sheriff's Deputy Lonnie Coburn, who was attempting to apprehend them.
Hall has a lifelong history of intellectual deficits, with school records identifying him as 'mentally retarded' on numerous occasions.
Hall’s siblings testified that as a child, he was slow with speech and learning.
Hall was subjected to horrific and constant abuse by his mother, who would beat him for being 'slow,' tie him to his bed, whip him, and bury him in the sand up to his neck.
Over a 40-year period, Hall underwent nine IQ evaluations, with scores ranging from 60 to 80.

Procedural Posture:

Freddie Lee Hall was convicted of two first-degree murders and sentenced to death in a Florida state trial court.
Hall was resentenced after a prior Supreme Court ruling, and again received the death penalty, which was affirmed by the Florida Supreme Court.
Following the U.S. Supreme Court's decision in Atkins v. Virginia, Hall filed a motion in state court alleging he had an intellectual disability and was therefore ineligible for execution.
The Florida trial court, applying a state statute that requires an IQ score of 70 or below to be considered intellectually disabled, rejected Hall’s claim because his IQ scores were above 70.
The Florida Supreme Court affirmed the trial court's decision, upholding the constitutionality of the state's rigid 70-point IQ cutoff.
The U.S. Supreme Court granted certiorari.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a state law that defines intellectual disability for capital punishment eligibility with a rigid IQ score cutoff of 70, thereby precluding consideration of other evidence of intellectual disability or the standard error of measurement for scores above 70, violate the Eighth Amendment's prohibition on cruel and unusual punishments?

Opinions:

Majority - Justice Kennedy

Yes, a state law that defines intellectual disability with a rigid IQ score cutoff violates the Eighth Amendment. This rigid rule creates an unacceptable risk that persons with intellectual disability will be executed. The Eighth Amendment’s prohibition on executing individuals with intellectual disability, established in Atkins v. Virginia, must be enforced in a manner consistent with established medical and professional standards. The clinical community unanimously agrees that IQ scores are not a single, fixed number but represent a range, due to the standard error of measurement (SEM) inherent in all such tests. Florida's law, by treating an IQ score of 71 as dispositive and barring all other evidence of intellectual disability, disregards this scientific reality and the diagnostic criteria relied upon in Atkins. The vast majority of states do not use such a rigid cutoff, reflecting a national consensus against the practice. A state must allow a defendant whose IQ score falls within the test’s margin of error to present additional evidence of intellectual disability, including deficits in adaptive functioning, to ensure the constitutional protection is meaningful.

Dissenting - Justice Alito

No, the Florida law does not violate the Eighth Amendment. The Court in Atkins v. Virginia explicitly left to the states the task of developing appropriate procedures for determining intellectual disability, acknowledging a lack of national consensus on methodology. The majority improperly supplants this state discretion with a uniform national rule based on the evolving standards of private professional associations rather than the laws enacted by state legislatures, which are the clearest evidence of contemporary values. There is no national consensus among states against Florida’s approach; the majority’s analysis is flawed by counting states that have abolished the death penalty. Florida’s system, which allows for multiple IQ tests, is a reasonable method for accounting for testing error, and the Court's new standard wrongly conflates the distinct prongs of intellectual functioning and adaptive deficits.

Analysis:

This decision significantly refines the constitutional standard established in Atkins v. Virginia by invalidating the use of a rigid IQ score as the sole determinant of intellectual disability in capital cases. By mandating consideration of the standard error of measurement (SEM), the Court effectively constitutionalized a key aspect of clinical diagnostic practice, limiting states' discretion in defining intellectual disability. The ruling ensures a more holistic and scientifically-grounded inquiry, requiring courts to consider adaptive functioning and other evidence for defendants with IQ scores near the generally accepted threshold. This precedent strengthens protections for defendants with potential intellectual disabilities and forces the few states with similar bright-line rules to amend their procedures.

Gunnerbot

AI-powered case assistant

Loaded: Hall v. Florida (2014)

Try: "What was the holding?" or "Explain the dissent"