Thompson v. State
Annotate this CaseAppellant was convicted of first-degree murder and sentenced to death. After the United States Supreme Court ruled in Atkins v. Virginia that it was unconstitutional to execute persons with intellectual disabilities, Appellant raised claims that he was intellectually disabled and could not be executed. The trial court and Supreme Court denied relief, relying, in part, on the bright-line cutoff of an IQ score of 70 that was subsequently invalidated in theUnited States Supreme Court’s holding in Hall v. Florida. This appeal concerned Appellant’s seventh motion for postconviction relief, alleging that his death sentence violated the Eighth and Fourteenth Amendments under Atkins. The postconviction court summarily denied Appellant’s motion. The Supreme Court reversed, holding that failing to give Appellant the benefit of Hall would result in a manifest injustice, which is an exception to the law of the case doctrine. Remanded for a new evidentiary hearing regarding intellectual disability, to be conducted pursuant to Hall.
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