Case: Hall v. Florida (2014)
Facts: Freddie Hall and his accomplice, kidnaped, beat, raped and murdered, a pregnant young woman, Karol Hurst. Afterwards they killed Lonnie Coburn, a sheriff’s deputy while they attempted to rob a store. Hall was sentenced to death for both murders.
At the time of Hall’s first sentence, Florida did not consider intellectual disability to be a mitigating factor.
The Supreme Court held capital defendants must be permitted to present mitigating evidence in Hitchcock v. Dugger.
In 2002 the US Supreme Court ruled the Eighth Amendment prohibited the execution of persons with intellectual disabilities in Atkins v. Virginia.
In Florida, someone must have an IQ test score of 70 or under to be considered intellectually…show more content… He presented evidence of his disability; medical experts said he was significantly retarded and his siblings testified he was challenged and abused as a child. The court still found him guilty; even with the substantial evidence, these mental difficulties does not justify or excuse the moral culpability of the crime.
After the Atkins ruling, Hall filed an appeal that he was intellectually disabled and shouldn’t be executed. He again presented his earlier evidence. His IQ test score was 71, while Florida has a cutoff score of 70 in order to be considered intellectually disabled. The Florida Supreme Court rejected his appeal and held the states qualification cutoff was constitutional. After the Supreme Court granted certiorari.
Issue: Does Florida’s IQ rule to determine if one is intellectually disabled violate the Eighth Amendment’s ban on cruel and unusual punishment?
Holding: (5 – 4) Yes it does violate the Eighth amendment.
Rationale: (Justice Kennedy) The Court holds that the Eighth and Fourteenth Amendments to the Constitution forbid the execution of persons with intellectual disability. Florida’s 70-point threshold creates an unacceptable risk that persons with intellectual disability will be executed, and this is unconstitutional. People with mental disabilities face a greater risk of wrongful execution since they are less likely to be able to defend themselves in