Hall v. Florida

Hall v. Florida, 572 U.S. 701 (2014), was a United States Supreme Court case in which the Court held that a bright-line IQ threshold requirement for determining whether someone has an intellectual disability (formerly mental retardation) is unconstitutional in deciding whether they are eligible for the death penalty.[1]

Hall v. Florida
Argued March 3, 2014
Decided May 27, 2014
Full case nameFreddie Lee Hall, Petitioner v. Florida
Docket no.12-10882
Citations572 U.S. 701 (more)
134 S. Ct. 1986; 188 L. Ed. 2d 1007
Case history
PriorHall v. State, 109 So. 3d 704 (Fla. 2012); cert. granted, 571 U.S. 973 (2013).
Holding
A Florida law allowing the execution of borderline mentally handicapped individuals violated the Eighth Amendment's prohibition of cruel and unusual punishments.
Court membership
Chief Justice
John Roberts
Associate Justices
Antonin Scalia · Anthony Kennedy
Clarence Thomas · Ruth Bader Ginsburg
Stephen Breyer · Samuel Alito
Sonia Sotomayor · Elena Kagan
Case opinions
MajorityKennedy, joined by Ginsburg, Breyer, Sotomayor, Kagan
DissentAlito, joined by Roberts, Scalia, Thomas

The case fleshed out standards first announced by the Court in Atkins v. Virginia, which left the determination of what constitutes intellectual disability to the states. In Atkins, the Court held that people are intellectually disabled and thus ineligible for the death penalty if these three conditions are met: 1.) “subaverage intellectual functioning,” meaning low I.Q. scores; 2.) a lack of fundamental social and practical skills; and 3.) the presence of both conditions before age 18.[2] The Atkins court stated I.Q. scores under “approximately 70” typically indicate disability, but the court let the states determine who is mentally disabled and thus cannot be executed.[2]

In Hall the Court narrowed the discretion under which U.S. states can designate an individual convicted of murder as too intellectually incapacitated to be executed.[3] 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.[4] 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.[5] Hall had scored a 71 instead of 70 on an I.Q. test.[2] Justice Anthony M. Kennedy wrote for the majority that this "rigid rule, the court now holds, creates an unacceptable risk that persons with an intellectual disability will be executed, and thus is unconstitutional."[5] If an individual claiming intellectual incapacity has an IQ score that falls somewhere between 70 and 75, then that individual’s lawyers must be allowed to offer additional clinical evidence of intellectual deficit, including, most importantly, the inability to learn basic skills and adapt to changing circumstances.[3]

The court also adopted the term "intellectually disabled" to replace "mentally retarded," which had been used in prior opinions. Intellectual disability is a condition characterized by significant limitations in both intellectual functioning and in adaptive behavior, which covers many everyday social and practical skills, and originates before the age of 18, according to the American Association on Intellectual and Developmental Disabilities,[6] and the term is preferred by the medical profession.[7]

See also

References
  1. "Hall v. Florida (docket number 12-10882)". SCOTUSblog. 27 May 2014. Retrieved 29 May 2014.
  2. Liptak, Adam (27 May 2014). "Court Extends Curbs on the Death Penalty in a Florida Ruling". The New York Times. Retrieved 29 May 2014.
  3. Denniston, Lyle (27 May 2014). "Opinion analysis: A new limit on the death penalty". SCOTUSblog. Retrieved 29 May 2014.
  4. Sherman, Mark. "High court rules for death-row inmates with low IQ". Associated Press. The Kansas City Star. Retrieved 29 May 2014.
  5. Savage, David (27 May 2014). "Supreme Court says IQ cannot determine mental fitness in capital cases". The Los Angeles Times. Retrieved 29 May 2014.
  6. "Definition of Intellectual Disability". American Association on Intellectual and Developmental Disabilities.
  7. Bravin, Jess (27 May 2014). "High Court Rejects Florida's IQ Standard for Death Penalty". The Wall Street Journal. Retrieved 29 May 2014.
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