Hall v. Florida

On February 21, 1978, Freddie Lee Hall and Mark Ruffin raped and murdered Karol Hurst. Hurst was 21-years-old and seven months pregnant. Afterwards, the pair murdered Lonnie Coburn, a sheriff's deputy, when he tried to apprehend them in a convenience store parking lot. The death penalty was applied under Penry v. Lynaugh because Atkins had not yet been decided when Hall was first sentenced. After the United States Supreme Court, in Hitchcock v. Dugger, held that mitigating evidence must be allowed, testimony of intellectual disability was presented at resentencing based on Hall's school and court records. After hearing the uncontested testimony, the jury decided to recommend the death penalty. The sentencing court accepted the recommendation. They found that there was "substantial evidence in the record" to support a finding that Hall had been "mentally retarded his entire life" but questioned the evidence presented by the defense experts: nothing of which the experts testified could explain how a psychotic, mentally-retarded, brain-damaged, learning-disabled, speech-impaired person could formulate a plan whereby a car was stolen and a convenience store was robbed. The Florida Supreme Court affirmed the sentence. In the 2002 case of Atkins v. Virginia, the court ruled that the Eighth Amendment prohibited the execution of the intellectually disabled. After the Atkins ruling, Hall challenged his death sentence on the grounds that he had an intellectual disability. Since his arrest, Hall had received nine I.Q tests, with scores ranging from 60 to 80. There was also significant evidence in school reports and court records of Hall's intellectual disability, a trial judge noted that he had been "mentally retarded his entire life". Hall presented an I.Q score of 71, however, under Florida Law, a person with an I.Q above 70 was not considered intellectually disabled. Hall's appeal to the Florida Supreme Court was dismissed, with the court holding that Florida's 70-point threshold was constitutional. == Judgment ==

In Hall, the Supreme Court held 5–4 that Florida's interpretation of the threshold requirement was unconstitutional. The Court narrowed the discretion under which U.S. states can designate an individual convicted of murder as too intellectually incapacitated to be executed. The Court prohibited states in borderline cases from relying only on intelligence test scores to determine whether a death row inmate is eligible to be executed. States must look beyond IQ scores when inmate tests are in the range of 70 to 75. IQ tests have a margin of error, and those inmates whose scores fall within the margin must be allowed to present other evidence of mental disability. The Court further held that the states may not use a "rigid rule" that denies leniency to defendants with severe mental disabilities simply because they score above 70 on an IQ test. Hall had scored a 71 instead of 70 on an I.Q. test. and the term is preferred by the medical profession. == Dissenting opinion ==

Justice Alito filed the dissenting opinion, he was joined by Chief Justice Roberts, Justice Scalia and Justice Thomas. In his dissent, Alito criticized the majority's reliance on the views of medical experts, saying that the Justices had overruled Atkins "based largely on the positions adopted by private professional organizations". He also argued that by overruling Atkins, the court had replaced the framework, established in previous Eighth Amendment cases, with a "uniform national rule that is conceptually unsound, and likely to result in confusion". == Commutation of Hall's death sentence ==

In September 2016, the Florida Supreme Court vacated Hall's death sentence, and re-sentenced him to life imprisonment. == See also ==