Quince v. StateAnnotate this Case
The Supreme Court affirmed the trial court’s order summarily denying Appellant’s renewed motion for a determination of intellectual disability as a bar to execution, filed under Fla. R. Crim. P. 3.203 and Fla. Stat. 921.137, holding that Appellant could not have met his burden to demonstrate that he was intellectually disabled.
Appellant pleaded guilty to first-degree felony murder and was sentenced to death. In 2015, in the wake of Hall v. Florida, 134 S. Ct. 1986 (2014), Appellant filed a renewed motion for a determination of intellectual disability as a bar to execution. After a hearing, the trial court concluded that Appellant failed to prove that he was intellectually disabled because none of the three IQ scores he had presented fell within the standard error of measurement of IQ tests. The Supreme Court affirmed, holding that because Appellant failed to meet the significantly subaverage intellectual functioning prong of he intellectual disability standard, he was not entitled to relief.