Woodall v. Commonwealth

The Supreme Court reversed the trial court’s denial of Defendant’s post-conviction motion requesting that the trial court declare him to be intellectually disabled, which would preclude the imposition of the death penalty, holding that Ky. Rev. Stat. 532.130(2), a statute with an outdated test for ascertaining intellectual disability, is unconstitutional under the Eighth Amendment to the United States Constitution.

Defendant was sentenced to death for the kidnapping, rape, and murder of a teenage girl. Eventually, Defendant filed a Ky. R. Civ. P. 60.02 and 60.03 motion alleging that he is intellectually disabled. The trial court denied the motion without conducting a hearing. The Supreme Court reversed and remanded the case to the trial court to conduct a hearing consistent with this opinion, holding that section 532.130(2) does not go far enough in recognizing that, in addition to ascertaining intellectual disability using a bright-line test to determine death-penalty-disqualifying intellectual disability, prevailing medical standards should always take precedence in a court’s determination.