Frank A. Walls v. State of Florida
213 So. 3d 340
Fla.2016Background
- Frank Walls was convicted of multiple offenses including first‑degree murder; sentenced to death for the murder of Ann Peterson after retrial. His penalty phase presented mental health and IQ evidence.
- Prior proceedings: multiple appeals and postconviction motions; earlier intellectual‑disability (then termed mental retardation) evidentiary hearing found IQ scores above 70 in juvenility, with later adult scores of 72 and 74; relief denied under the pre‑Hall 70 cutoff.
- Walls filed a successive 3.851 motion after the U.S. Supreme Court’s Hall v. Florida decision, arguing Hall’s rejection of Florida’s rigid IQ‑70 cutoff meant he was entitled to a new holistic hearing considering IQ SEM and adaptive deficits.
- The circuit court summarily denied the successive motion, concluding (1) Walls lacked IQ scores under 75 before age 18 and (2) he had previously had a hearing on the issue; it did not definitively rule on Hall’s retroactivity.
- The Florida Supreme Court held Hall is retroactive under Florida’s retroactivity test and reversed the summary denial, remanding for a new evidentiary hearing applying Hall’s standards (holistic review of all three prongs and consideration of IQ SEM).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hall v. Florida applies retroactively to Walls | Hall is a U.S. Supreme Court constitutional decision that is a development of fundamental significance warranting retroactive application under Witt | Hall is an evolutionary/procedural refinement that should not be applied retroactively; it does not place beyond the State’s power any class of persons | Majority: Hall is retroactive under Witt as a development of fundamental significance removing from the State’s authority some death sentences; remand for new hearing |
| Whether summary denial was proper given Walls’ juvenile IQ scores | Even though juvenile IQs were high, Hall requires a holistic review (IQ SEM + adaptive deficits + onset) and prior hearing under a 70 cutoff was inadequate | Walls’ juvenile IQs (102, 101) preclude showing onset before 18, so claim fails as a matter of law; summary denial proper | Majority: Prior hearing used unconstitutional standard; summary denial reversed and new evidentiary hearing required (court did not reach juvenile‑onset question) |
| Scope of Hall’s holding (must courts permit full presentation when IQ >70 but ≤75) | Hall rejects a rigid 70 cutoff and requires courts to consider IQ SEM and allow presentation of adaptive‑functioning and onset evidence when IQ falls in SEM range | Hall only requires consideration of SEM up to about 75; it does not eliminate the statutory threshold requirement that intellectual functioning be significantly subaverage | Majority: Hall mandates holistic, conjunctive/interrelated consideration of the three prongs; no single factor dispositive; courts must permit full presentation under Hall’s framework |
| Remedy available to Walls | New evidentiary hearing under rule 3.203/3.851 applying Hall and current standards | No new relief; prior hearing sufficed and juvenile IQs defeat claim | Held: Remand for a new evidentiary hearing under Hall standards; summary denial reversed |
Key Cases Cited
- Hall v. Florida, 134 S. Ct. 1986 (U.S. 2014) (Florida’s strict IQ‑70 cutoff unconstitutional; courts must consider IQ SEM and allow additional adaptive‑functioning evidence)
- Walls v. State, 926 So.2d 1156 (Fla. 2006) (reciting facts and procedural history of Walls’ convictions and prior appeals)
- Oats v. State, 181 So.3d 457 (Fla. 2015) (explaining Hall’s mandate that all three prongs be considered conjunctively and no single factor be dispositive)
- Witt v. State, 387 So.2d 922 (Fla. 1980) (Florida retroactivity framework for applying new decisions)
- Montgomery v. Louisiana, 136 S. Ct. 718 (U.S. 2016) (distinguishing substantive versus procedural new rules for retroactivity)