Hall v. Florida
134 S. Ct. 1986
| SCOTUS | 2014Background
- Hall challenged Florida’s IQ cutoff of 70 as a threshold to present intellectual disability evidence in capital sentencing.
- Evidence showed Hall consistently scored around 71 on IQ tests; scores ranged from 60 to 80 across decades.
- Florida courts treated 70 or below as mandatory to consider IQ-based disability evidence, blocking further inquiry when above 70.
- The Florida Supreme Court affirmed the 70-point threshold, rejecting Hall’s claim of unconstitutional sentencing procedure.
- The U.S. Supreme Court reversed, holding Florida’s fixed cutoff disregarded SEM and the requirement to consider adaptive deficits.
- Court held that when IQ falls within the test’s margin of error, courts must allow additional evidence of intellectual disability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Florida’s 70 IQ cutoff violates Atkins and the Eighth Amendment. | Hall argues SEM and adaptive deficits must be considered. | Florida maintains a strict 70 cutoff aligned with statutory definition. | Unconstitutional; Florida's cutoff invalid. |
| Whether SEM must inform the disability determination in capital cases. | Court must consider score ranges due to SEM; allow additional evidence if within margin. | SEM not required; Florida can rely on multiple IQ scores. | SEM must be considered for individual assessments. |
| Whether Florida’s approach protects against wrongful executions and maintains trial integrity. | Strict cutoff risks executing intellectually disabled individuals. | Florida’s method reduces unwarranted reliance on a single number and allows additional evidence. | Court agrees Florida approach undermines reliability under Eighth Amendment. |
Key Cases Cited
- Atkins v. Virginia, 536 U. S. 304 (2002) (death penalty blocked for intellectually disabled)
- Roper v. Simmons, 543 U. S. 551 (2005) (evolving standards and dignity in punishment)
- Penry v. Lynaugh, 492 U. S. 302 (1989) (evolving standards and legislature as evidence)
- Bobby v. Bies, 556 U. S. 825 (2009) (procedural guidance on disability determinations)
- Ford v. Wainwright, 477 U. S. 399 (1986) (states’ task in enforcing constitutional restriction)