Hall v. Florida

572 U.S. ___ (2014); 134 S.Ct. 1986
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The petitioner and his accomplice kidnapped, beat, raped, and murdered a pregnant woman before driving to a convenience store, which they planned to rob. In the parking lot of the store, they killed a sheriff’s deputy who attempted to apprehend them. The petitioner received the death penalty for both murders. He argued that he could not receive the death penalty due to his intellectual disability. When the petitioner was first sentenced, the Supreme Court had not yet ruled that the Eighth Amendment to the U.S. Constitution prohibits states from imposing the death penalty on persons with an intellectual disability.

Later, the Supreme Court held that capital defendants must be allowed to present mitigating evidence in death penalty proceedings. Subsequently, the petitioner provided unchallenged evidence of an intellectual disability. Despite this evidence, the petitioner was resentenced to the death penalty. The petitioner’s appeal was denied in state court on the basis that Florida law required that a person’s IQ must be shown to be 70 or below before he or she could present any additional evidence of intellectual disability, and the petitioner’s IQ had been shown to be 71.

A Florida statute defined intellectual disability as “significantly subaverage general intellectual functioning existing concurrently with deficits in adaptive behavior and manifested during the period from conception to age 18” and “significantly subaverage general intellectual functioning” as “performance that is two or more standard deviations from the mean score on a standardized intelligence test.” Two standard deviations from the mean would be a score of approximately 70 points. The Eighth Amendment provides that “[e]xcessive bail shall not be required, nor excessive fines imposed, nor cruel and unusual punishments inflicted.”

The Court held that Florida's statute, which disallowed defendants from presenting additional evidence of intellectual disability if the defendant’s IQ score was over 70, violated the Eighth Amendment of the Constitution by creating an unacceptable risk that persons with intellectual disability would be sentenced to the death penalty. The Court reasoned that Florida’s statute disregarded established medical practice in two ways: it took an IQ score as final and conclusive evidence of intellectual capacity when experts in the field would consider other evidence, and it relied on a purportedly scientific measurement (IQ) while refusing to recognize that the measurement is imprecise. The professionals who design and interpret IQ tests agreed that IQ test scores should be read as a range and not as a single fixed number. The Court felt that there was strong evidence of consensus that our society does not regard the strict IQ cutoff as proper or humane, and that the IQ test is imprecise (although it can be helpful).

The dissenting Justices stated that this decision would create a uniform national rule that is “conceptually unsound and likely to result in confusion.” They felt that state legislatures were best equipped to figure out modern values, and that legislatures, not the courts, should respond to the will and morals of the people.

“Intellectual disability is a condition, not a number . . . . Courts must recognize, as does the medical community, that the IQ test is imprecise. This is not to say that an IQ test score is unhelpful. It is of considerable significance, as the medical community recognizes. But in using these scores to assess a defendant’s eligibility for the death penalty, a State must afford these test scores the same studied skepticism that those who design and usethe tests do, and understand that an IQ test score represents a range rather than a fixed number. A State that ignores the inherent imprecision of these tests risks executing a person who suffers from intellectual disability.” Page 21 (citations omitted).

“The death penalty is the gravest sentence our society may impose. Persons facing that most severe sanction must have a fair opportunity to show that the Constitution prohibits their execution. Florida’s law contravenes our Nation’s commitment to dignity and its duty to teach human decency as the mark of a civilized world. The States are laboratories for experimentation, but those experiments may not deny the basic dignity the Constitution protects.” Page 22.

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