Oats v. State
Annotate this CaseDefendant was tried and convicted of the 1979 robbery of a convenience store and the first-degree murder of the store clerk. Defendant later filed a motion seeking to vacate his death sentence on the ground that he is intellectually disabled. After an evidentiary hearing, the circuit court denied the motion, concluding that Defendant was not intellectually disabled because he was unable to establish that his intellectual disability manifested prior to the age of eighteen - one of the three required prongs in Florida’s statutory test for determining an intellectual disability. The Supreme Court reversed, holding (1) in light of the United States Supreme Court’s decision in Hall v. Florida, the circuit court’s order should have addressed all three prongs of the intellectual disability test rather than a single factor; (2) the circuit court erred in concluding that Defendant failed to meet his burden of establishing his intellectual disability without considering or weighing all of the testimony that Defendant presented; and (3) the circuit court erred in other aspects of its legal analysis. Remanded.
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