__ U.S. __ (2014), 12-10882, Hall v. Florida
|Citation:||__ U.S. __, 134 S.Ct. 1986, 188 L.Ed.2d 1007, 82 U.S.L.W. 4373, 24 Fla.L.Weekly Fed. S 779|
|Opinion Judge:||Kennedy Justice.|
|Party Name:||FREDDIE LEE HALL, Petitioner v. FLORIDA|
|Attorney:||Seth P. Waxman argued the cause for petitioner. Allen Winsor argued the cause for respondent.|
|Judge Panel:||Kennedy, J., delivered the opinion of the court, in which Ginsburg, Breyer, Sotomayor, and Kagan, JJ., Joined. Alito, J., filed a dissenting opinion, In Which Roberts, C. J., and Scalia and Thomas, JJ., Joined. Justice Alito, with whom The Chief Justice, Justice Scalia, and Justice Thomas join, d...|
|Case Date:||May 27, 2014|
|Court:||United States Supreme Court|
Argued March 3, 2014.
[134 S.Ct. 1987] ON WRIT OF CERTIORARI TO THE SUPREME COURT OF FLORIDA
Reversed and remanded.
DECISION: Florida statutory threshold, as interpreted by state's highest court to require accused to show IQ score of 70 or below before being permitted to present additional evidence of intellectual disability precluding death penalty, held to violate Federal Constitution's Eighth Amendment.
[134 S.Ct. 1988] After this Court held that the Eighth and Fourteenth Amendments forbid the execution of persons with intellectual disability, see Atkins
v. Virginia, 536 U.S. 304, 321, 122 S.Ct. 2242, 153 L.Ed.2d 335, Hall asked a Florida state court to vacate his sentence, presenting evidence that included an IQ test score of 71. The court denied his motion, determining that a Florida statute mandated that he show an IQ score of 70 or below before being permitted to present any additional intellectual disability evidence. The State Supreme Court rejected Hall's appeal, finding the State's 70-point threshold constitutional.
Held: The State's threshold requirement, as interpreted by the Florida Supreme Court, is unconstitutional. Pp. ___ - ___, 188 L.Ed.2d, at 1016-1026.
(a) The Eighth Amendment, which " reaffirms the duty of the government to respect the dignity of all persons," Roper v. Simmons, 543 U.S. 551, 560, 125 S.Ct. 1183, 161 L.Ed.2d 1, prohibits the execution of persons with intellectual disability. No legitimate penological purpose is served by executing the intellectually disabled. Atkins, 563 U.S., at 317, 320, 122 S.Ct. 2242, 153 L.Ed.2d 335. Prohibiting such executions also protects the integrity of the trial process for individuals who face " a special risk of wrongful execution" because they are more likely to give false confessions, are often poor witnesses, and are less able to give meaningful assistance to their counsel. Id., at 320-321, 122 S.Ct. 2242, 153 L.Ed.2d 335. In determining whether Florida's intellectual disability definition implements these principles and Atkins' holding, it is proper to consider the psychiatric and professional studies that elaborate on the purpose and meaning of IQ scores and how the scores relate to Atkins, and to consider how the several States have implemented Atkins . Pp. ___ - ___, 188 L.Ed.2d, at 1016-1018.
(b) Florida's rule disregards established medical practice. On its face, Florida's statute could be consistent with the views of the medical community discussed in Atkins and with the conclusions reached here. It defines intellectual disability as the existence of concurrent deficits in intellectual and adaptive functioning, long the defining characteristic of intellectual disability. See Atkins, supra, at 308, 122 S.Ct. 2242, 153 L.Ed.2d 335. And nothing in the statute precludes Florida from considering an IQ test's standard error of measurement (SEM), a statistical fact reflecting the test's inherent imprecision and acknowledging that an individual score is best understood as a range, e.g., five points on either side of the recorded score. As interpreted by the Florida Supreme Court, however, Florida's rule disregards established medical practice in two interrelated ways: It takes an IQ score as final and conclusive evidence of a defendant's intellectual capacity, when experts would consider other evidence; and it relies on a purportedly scientific measurement of a defendant's abilities, while refusing to recognize that measurement's inherent imprecision. While professionals have long agreed that IQ test scores should be read as a range, Florida uses the test score as a fixed number, thus barring further consideration of other relevant evidence, e.g., deficits in adaptive functioning, including evidence of past performance, environment, and upbringing. Pp. ___ - ___, 188 L.Ed.2d, at 1018-1020.
(c) The rejection of a strict 70-point cutoff in the vast majority of States and a " consistency in the trend," Roper, supra, at 567, 125 S.Ct. 1183, 161 L.Ed.2d 1, toward recognizing
[134 S.Ct. 1989] the SEM provide strong evidence of consensus that society does not regard this strict cutoff as proper or humane. At most, nine States mandate a strict IQ score cutoff at 70. Thus, in 41 States, an individual in Hall's position would not be deemed automatically eligible for the death penalty. The direction of change has been consistent. Since Atkins, many States have passed legislation to comply with the constitutional requirement that persons with intellectual disability not be executed. Two of those States appear to set a strict cutoff at 70, but at least 11 others have either abolished the death penalty or passed legislation allowing defendants to present additional intellectual disability evidence when their IQ score is above 70. Every state legislature, save one, to have considered the issue after Atkins and whose law has been interpreted by its courts has taken a position contrary to Florida's. Pp. ___ - ___, 188 L.Ed.2d, at 1020-1023.
(d) Atkins acknowledges the inherent error in IQ testing and provides substantial guidance on the definition of intellectual disability. The States play a critical role in advancing the protections of Atkins and providing this Court with an understanding of how intellectual disability should be measured and assessed, but Atkins did not give them unfettered discretion to define the full scope of the constitutional protection. Clinical definitions for intellectual disability which, by their express terms, rejected a strict IQ test score cutoff at 70, and which have long included the SEM, were a fundamental premise of Atkins. See 536 U.S., at 309, 122 S.Ct. 2242, 153 L.Ed.2d 335. A fleeting mention of Florida in a citation listing States that had outlawed the execution of the intellectually disabled, id., at 315, 122 S.Ct. 2242, 153 L.Ed.2d 335, did not signal the Atkins Court's approval of the State's current understanding of its law, which had not yet been interpreted by the Florida Supreme Court to require a strict 70-point cutoff. Pp. ___ - ___, 188 L.Ed.2d, at 1023-1024.
(e) When a defendant's IQ test score falls within the test's acknowledged and inherent margin of error, the defendant must be able to present additional evidence of intellectual disability, including testimony regarding adaptive deficits. This legal determination of intellectual disability is distinct from a medical diagnosis but is informed by the medical community's diagnostic framework, which is of particular help here, where no alternative intellectual disability definition is presented, and where this Court and the States have placed substantial reliance on the medical profession's expertise. Pp. ___ - ___, 188 L.Ed.2d, at 1024-1026.
109 So.3d 704, reversed and remanded.
[134 S.Ct. 1990]
This Court has held that the Eighth and Fourteenth Amendments to the Constitution forbid the execution of persons with intellectual disability. Atkins
v. Virginia, 536 U.S. 304, 321, 122 S.Ct. 2242, 153 L.Ed.2d 335 (2002). Florida law defines intellectual disability to require an IQ test score of 70 or less. If, from test scores, a prisoner is deemed to have an IQ above 70, all further exploration of intellectual disability is foreclosed. This rigid rule, the Court now holds, creates an unacceptable risk that persons with intellectual disability will be executed, and thus is unconstitutional.
On February 21, 1978, Freddie Lee Hall, petitioner here, and his accomplice, Mark Ruffin, kidnaped, beat, raped, and murdered Karol Hurst, a pregnant, 21-year-old newlywed. Afterward, Hall and Ruffin drove to a convenience store they planned to rob. In the parking lot of the store, they killed Lonnie Coburn, a sheriff's deputy who attempted to apprehend them. Hall received the death penalty for both murders, although his sentence for the Coburn murder was later reduced on account of insufficient evidence of premeditation. Hall v. Florida, 403 So.2d 1319, 1321 (Fla. 1981) ( per curiam ).
Hall argues that he cannot be executed because of his intellectual disability. Previous opinions of this Court have employed the term " mental retardation." This opinion uses the term " intellectual disability" to describe the identical phenomenon. See Rosa's Law, 124 Stat. 2643 (changing entries in the U.S. Code from " mental retardation" to " intellectual disability" ); Schalock et. al, The Renaming of Mental Retardation : Understanding the Change to the Term Intellectual Disability, 45 Intellectual & Developmental Disabilities 116 (2007). This change in terminology is approved and used in the latest edition of the Diagnostic and Statistical Manual of Mental Disorders, one of the basic texts used by psychiatrists and other experts; the manual is often referred to by its initials " DSM," followed by its edition number, e.g., " DSM-5." See American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders 33 (5th ed. 2013).
When Hall was first sentenced, this Court had not yet ruled that the Eighth Amendment prohibits States from imposing the death penalty on persons with intellectual disability. See Penry
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