Walls v. StateAnnotate this Case
Appellant was convicted of felony murder in the death of Edward Alger and premeditated and felony murder in the death of Ann Peterson. The trial judge sentenced Appellant to death for Peterson’s murder and to life imprisonment for Alger’s murder. In 2006, Appellant filed his first successive postconviction motion, alleging that his death sentence was improper because he was intellectually disabled. The circuit court denied relief after an evidentiary hearing. In 2015, Appellant filed his second successive postconviction motion, arguing that his death sentence was unconstitutional because the United States Supreme Court’s decision in Hall v. Florida changed the definition of subaverage intellectual function to include IQ scores that are 75 or below, and because the previous intellectual disability hearing was directed at satisfying the constitutional definition of an IQ that is 70 or below, he was entitled to a new hearing. The circuit court summarily denied Appellant’s successive motion without granting a hearing. The Supreme Court reversed, holding (1) Hall applies retroactively; and (2) Appellant was entitled to a new evidentiary hearing as to his claim of intellectual disability.