LOCATION: Leesburg, Florida
DOCKET NO.: 12-10882
DECIDED BY: Roberts Court (2010-2016)
CITATION: 572 US (2014)
GRANTED: Oct 21, 2013
ARGUED: Mar 03, 2014
DECIDED: May 27, 2014
Seth P. Waxman - for the petitioner
Facts of the case
Freddie Lee Hall was tried, convicted, and sentenced to death for the 1978 murder of Karol Hurst. Hall sought a writ of habeas corpus and a stay of execution in state court, which was denied. Hall then sought a writ of habeas corpus in federal court and was denied without an evidentiary hearing. Hall appealed to the U.S. Court of Appeals for the Eleventh Circuit, which reversed in part and remanded the case for a hearing regarding the potential effect of his absence from the courtroom during the trial and ineffective counsel. On remand, the district court again denied habeas corpus and held that Hall's absences from the courtroom were harmless and that he deliberately bypassed ineffective counsel claims. The Court of Appeals affirmed.
Hall petitioned the Supreme Court of Florida for habeas corpus relief based on the Supreme Court decision in Hitchcock v. Dugger, which held that all mitigating factors should be considered rather than just the mitigating factors listed in the relevant statutes. The Supreme Court of Florida denied the petition and held that no error occurred in sentencing. After the governor signed his second death warrant, Hall filed a motion to vacate the sentence, which the trial court denied by holding that the Supreme Court of Florida's decision barred further review of the case. The Supreme Court of Florida disagreed and held that the case involved additional non-record facts that had not been considered in the previous review. The case was vacated and remanded for new sentencing. At the new sentencing trial, the trial court held that Hall's mental retardation was a mitigating factor with "unquantifiable weight," and he was again sentenced to death. The Supreme Court of Florida affirmed.
In 2002, the Supreme Court decided the case Atkins v. Virginia, in which the Court held that the execution of mentally retarded defendants constituted cruel and unusual punishment in violation of the Eighth Amendment. Hall filed a motion to declare certain sections of the Florida death penalty statute unconstitutional based on this decision and filed a claim to be exempt from the death penalty under that ruling. The trial court held a hearing to determine if Hall was eligible for such a claim and found that he was not because the first prong of the test—whether he had an IQ below 70—could not be met. The Supreme Court of Florida affirmed.
Does the Florida scheme for identifying mentally retarded defendants in capital punishment cases violate the standards established in Atkins v. Virginia?
Media for Hall v. FloridaAudio Transcription for Oral Argument - March 03, 2014 in Hall v. Florida
Audio Transcription for Opinion Announcement - May 27, 2014 in Hall v. Florida
Justice Kennedy has the opinion this morning in case 12-10882, Hall versus Florida.
The opinion addresses in this case the claim by the petitioner Freddie Lee Hall.
Hall has been convicted of murder and sentenced to death by the State of Florida.
After his first sentencing hearing there was a second.
There, Hall presented substantial evidence of intellectual disability.
This included school records, professional diagnoses and -- and testimony by his delayed development.
There was also evidence that he was raised in the words of the sentencing judge under the most horrible family circumstances possible.
In the opinion we counsel this in more detail.
Hall was again given the death sentence.
Then in 2002, this Court decided Atkins versus Virginia.
Atkins case held by the person with intellectual disability cannot be sentenced to death.
Hall had still another sentencing proceeding to consider his Atkins claim, and that is the sentencing proceeding, that's the issue here.
There was evidence of Hall's low IQ of course including a test score of 71 but the Florida Supreme Court interprets a Florida statute implementing Atkins to define intellectual disability to require an IQ score of 70 or lower.
And since Hall's relevant score was 71, one point above the floor the limit, it held Atkins to be inapplicable.
As a result, the substantial evidence of Hall's developmental disabilities was deemed not relevant to the constitutional claim raised under Atkins.
Because Hall's lowest test score was 71, one point above the Florida cutoff of 70.
He was not allowed to present other evidence showing deficits and adaptive functioning is bearing upon his intellectual disability for the purpose of invoking the protection with Atkins.
This Court now holds that Florida's ruling setting 70 or below as an absolute cutoff point is unconstitutional.
To understand why Florida's law violated the Eighth Amendment, as applied to the states by the Fourteenth, it is necessary to delve briefly into the area of statistics as the opinion further discusses.
The professionals who design and administer and interpret IQ test have long agreed that an IQ score should not be viewed as a single fixed number, but is a range.
And the range is calculated using a statistical technique called the standard error of measurement and SEM is the common abbreviation for standard error of measurement.
The latest edition of the Diagnostic and Statistical Manual of Mental Disorders one of the basic texts that is used by psychiatrist and other experts states that IQ scores have a general margin for measurement of error of approximately five points.
So when an IQ score of 71, is best interpreted according to the professionals, has a range between 66 and 76.
This is to simplify somewhat an application of the SEM, standard error of measurement.
In the significant majority of states in the nation, an individual in Hall's position would not be deemed automatically eligible for the death penalty.
Only two other state legislatures of adoptive strict 70-point cutoffs that have been interpreted identically to Florida.
A handful of other states have laws that could be interpreted similarly, but one state that has passed legislation since Atkins has allowed for the margin of error, and no state that previously allowed other evidence to be presented in cases like Halls has changed its statute to adopt the strict cutoff like Florida's.
Florida law also contradicts the unanimous consensus of the medical community.
While -- while the views of excerpts do -- do not dictate this Court's decision, the court does not disregard these informed assessments, and those professional authorities all agree that the intellectual disability is best considered as a condition, not a number.
No recognized professional in the medical -- in the mental health field supports the bright line cutoff at 70 that the Florida law requires.