Juan David Rodriguez v. State of Florida
219 So. 3d 751
| Fla. | 2017Background
- Juan David Rodriguez was convicted of first-degree murder and related crimes for a 1988 killing; a jury unanimously recommended death and the sentence was imposed and affirmed on direct appeal.
- Rodriguez pursued multiple postconviction proceedings alleging intellectual disability under Atkins and related Florida Rule 3.851 claims; experts produced conflicting IQ and adaptive-functioning evidence across hearings.
- A prior evidentiary Atkins hearing and subsequent appeals found Rodriguez did not establish intellectual disability (no reliable IQ <70, insufficient adaptive deficits, or onset before age 18).
- Rodriguez filed a second successive postconviction motion after Hall v. Florida; the circuit court summarily denied relief, finding the record conclusively refuted his Hall claim.
- Rodriguez also sought relief under Hurst v. Florida; the court rejected Hurst relief as nonretroactive to cases final before Ring.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hall requires a new evidentiary hearing on intellectual disability | Hall requires courts to defer to medical-community standards and to allow reconsideration of prior credibility findings and testing accommodations | Prior proceedings already afforded full Atkins protections; record conclusively refutes disability claims and credibility findings were supported by evidence | Denied — summary denial affirmed; Hall does not mandate overturning credibility findings and record refutes claim |
| Whether courts must make credibility findings consistent with AAIDD/medical authorities | Court should apply AAIDD-informed standards and not discard expert opinions inconsistent with previous case law | Hall does not compel adherence to every medical guide; trial courts may weigh expert testimony and make credibility determinations | Denied — Hall informs but does not remove trial-court factfinding or require blind adoption of medical guides |
| Whether one prong (e.g., IQ) was treated as dispositive in violation of Hall/Oats | Prior rulings improperly relied on a single factor, requiring Hall relief | Circuit court considered all three prongs (IQ, adaptive deficits, onset) and evaluated them holistically | Denied — record shows all three prongs were considered; no single-prong error like in Oats/Cardona |
| Whether Rodriguez is entitled to Hurst relief | Hurst renders Florida’s capital sentencing unconstitutional and applies to his case | Hurst is not retroactive to cases final before Ring; Rodriguez’s sentence became final in 1993 | Denied — Hurst relief not available retroactively; death sentence affirmed |
Key Cases Cited
- Hall v. Florida, 134 S. Ct. 1986 (2014) (Supreme Court held strict IQ cutoff invalid and required consideration of medical standards in Atkins inquiries)
- Hurst v. Florida, 136 S. Ct. 616 (2016) (Supreme Court held Florida’s sentencing scheme unconstitutional under Sixth Amendment)
- Atkins v. Virginia, 536 U.S. 304 (2002) (death penalty unconstitutional for intellectually disabled defendants)
- Oats v. State, 181 So. 3d 457 (Fla. 2015) (Florida requires holistic three-prong analysis under Hall)
- Cardona v. State, 185 So. 3d 514 (Fla. 2016) (trial court erred by ignoring expert-recommended testing accommodations and making IQ dispositive)
- Mann v. State, 112 So. 3d 1158 (Fla. 2013) (standard for summary denial of postconviction claims; legal sufficiency and record refutation)
- Brumfield v. Cain, 135 S. Ct. 2269 (2015) (Supreme Court discussed evidentiary standards for intellectual disability claims)
- Rodriguez v. State, 609 So. 2d 493 (Fla. 1992) (direct appeal affirming convictions and death sentence)