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Hall v. Florida

United States Supreme Court

572 U.S. 701 (2014)

Facts

Freddie Hall (defendant) was found guilty of murder for the killing of Karol Hurst and sentenced to death. Hall and an accomplice had kidnapped, beaten, raped, and killed Hurst who was pregnant at the time of her death. Hall’s original death sentence for murder was overturned because he had been barred from presenting evidence of his intellectual disability because it was considered nonstatutory mitigating evidence. Hall was resentenced. This time, Hall was permitted to present evidence of his intellectual disability. Hall had an IQ of 72. Despite the sentencing judge finding that Hall was mentally retarded, Hall was sentenced to death a second time. Hall moved to set aside his death sentence, which was denied. The Florida Supreme Court affirmed the denial. Florida law foreclosed consideration of intellectual disability as a mitigating circumstance for all defendants deemed to have an IQ above 70. Hall appealed, arguing that Florida’s strict IQ cutoff failed to consider other evidence of intellectual capacity and did not recognize the imprecise nature of IQ tests by ignoring the standard error of measurement (SEM). Thus, the cutoff violated the Eighth Amendment to the United States Constitution’s prohibition on the execution of persons with intellectual disabilities. The United States Supreme Court granted certiorari.

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Holding and Reasoning (Kennedy, J.)

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Dissent (Alito, J.)

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