Hall v. State
Annotate this CaseAppellant was convicted of murder and sentenced to death. After the Supreme Court decided in Atkins v. Virginia that the Eighth Amendment prohibits the execution of a person with an intellectual disability, Appellant filed a successive motion to vacate his sentence. The circuit court denied Appellant’s claim. The Fifth Circuit affirmed, concluding that the Supreme Court’s interpretation, in Cherry v. State, of Fla. Stat. 921.137(1) was proper. The Supreme Court affirmed, holding that the circuit court properly denied Appellant’s claim where Appellant failed to establish that his IQ was below 70. The United States Supreme Court reversed, holding that Florida courts may not have a bright-line cutoff IQ test score where it bars the consideration of other evidence of deficits in intellectual and adaptive functioning. On remand, the Supreme Court vacated Appellant’s death sentence and remanded with instructions to enter a life sentence, holding that Appellant presented sufficient evidence that he met the clinical and statutory definition of intellectual disability.
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