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.

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. 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.

On February 21, 1978, Freddie Lee Hall and Mark Ruffin raped and murdered Karol Hurst. Hurst was 21-years-old and seven months pregnant. Afterwards, the pair murdered Lonnie Coburn, a sheriff's deputy, when he tried to apprehend them in a convenience store parking lot.

The death penalty was applied under Penry v. Lynaugh because Atkins had not yet been decided when Hall was first sentenced. After the United States Supreme Court, in Hitchcock v. Dugger, held that mitigating evidence must be allowed, testimony of intellectual disability was presented at resentencing based on Hall's school and court records. After hearing the uncontested testimony, the jury decided to recommend the death penalty.

The sentencing court accepted the recommendation. They found that there was "substantial evidence in the record" to support a finding that Hall had been "mentally retarded his entire life" but questioned the evidence presented by the defense experts:

nothing of which the experts testified could explain how a psychotic, mentally-retarded, brain-damaged, learning-disabled, speech-impaired person could formulate a plan whereby a car was stolen and a convenience store was robbed.

The Florida Supreme Court affirmed the sentence.

In the 2002 case of Atkins v. Virginia, the court ruled that the Eighth Amendment prohibited the execution of the intellectually disabled. After the Atkins ruling, Hall challenged his death sentence on the grounds that he had an intellectual disability. Since his arrest, Hall had received nine I.Q tests, with scores ranging from 60 to 80. There was also significant evidence in school reports and court records of Hall's intellectual disability, a trial judge noted that he had been "mentally retarded his entire life". Hall presented an I.Q score of 71, however, under Florida Law, a person with an I.Q above 70 was not considered intellectually disabled. Hall's appeal to the Florida Supreme Court was dismissed, with the court holding that Florida's 70-point threshold was constitutional.