Phillips v. StateAnnotate this Case
The Supreme Court affirmed the order of the circuit court summarily denying Appellant's successive motion for postconviction relief filed under Fla. R. Crim. P. 3.851, holding that Walls v. State, 213 So. 3d 340 (Fla. 2016), is no longer good law.
In 1998, Appellant was convicted of murder and sentenced to death. In 2006, Appellant sought postconviction relief on his claim that he was intellectually disabled and, therefore, constitutionally ineligible for the death penalty. The postconviction court denied relief, and the Supreme Court affirmed. In the instant postconviction petition, Appellant sought another determination of his intellectual disability. Appellant relied in part on the Supreme Court's decision in Walls v. State, in which the Court held that the United States Supreme Court's decision in Hall v. Florida, 472 U.S. 701 (2014), is retroactive to cases where there has already been a finding that the defendant is not intellectually disabled. The Supreme Court affirmed, holding (1) this Court in Walls clearly erred in concluding that Hall applies retroactively, and this Court should not continue to apply the erroneous reasoning of Walls; and (2) therefore, the circuit court did not err in denying relief.