Hall v. Florida

An IQ threshold requirement, which bars a defendant from presenting intellectual disability evidence, is unconstitutional when that requirement disregards established medical practice, ignores inherent imprecision of an IQ test, and is inconsistent with the majority of the States’ legislation.

Petitioner murdered a woman and then killed a sheriff’s deputy who attempted to apprehend him. Petitioner received the death penalty for both murders, but his sentence for the second was reduced due to insufficient evidence of premeditation.

Petitioner asked a Florida state court to vacate his sentence, and presented evidence that included an IQ test of 71. The court denied Petitioner’s motion, explaining that a Florida statute required Petitioner to show an IQ score of 70 or below before being allowed to present evidence of intellectual disability. The State Supreme Court affirmed, and found Florida’s 70-point cutoff to be constitutional.

The United States Supreme Court held Florida’s requirement to be unconstitutional for several reasons. First, the Court determined that the statute disregards established medical practice because it regards an IQ score as conclusive evidence of a defendant’s intellectual capacity when experts would consider other evidence. Second, the Court explained that the statute ignores the inherent imprecision of an IQ test. Third, the Court stated that the statute bars consideration of relevant evidence of a defendant’s deficits in adaptive functioning. Finally, the Court highlighted that Petitioner would not be automatically eligible for the death penalty in 41 of the 50 States.