Sonny Boy Oats, Jr. v. State of Florida
181 So. 3d 457
| Fla. | 2015Background
- Sonny Boy Oats, Jr. was convicted of 1979 robbery and first-degree murder and sentenced to death; he later filed a Rule 3.203 motion claiming intellectual disability (formerly “mental retardation”) that would make him ineligible for execution.
- Multiple IQ tests over decades consistently placed Oats in the 54–67 range; experts and the State previously (1990 proceedings) conceded he fell in the mildly intellectually disabled range under DSM criteria.
- Evidence includes longstanding adaptive deficits (poor school performance, inability to hold steady employment, functional literacy limits), childhood head injuries and abuse, and a school screening (Slosson) at age 13 showing IQ ≈70.
- In the 2005 evidentiary hearing, defense experts diagnosed intellectual disability with onset in childhood; the State’s expert disputed onset before age 18 and questioned the reliability of childhood testing.
- The circuit court denied Oats’s Rule 3.203 motion solely on the ground he failed to prove manifestation before age 18, treating “manifested” effectively as requiring a childhood diagnosis or confirmatory pre-18 Wechsler/Stanford-Binet test.
- The Florida Supreme Court reversed and remanded: court held the trial court misapplied legal standards post–Hall and Brumfield, failed to consider all prior evidence (including the 1990 record), and conflated “manifested” with “diagnosed.”
Issues
| Issue | Oats’ Argument | State’s Argument | Held |
|---|---|---|---|
| Whether Oats is intellectually disabled and thus ineligible for death | Oats: IQ and adaptive deficits prove intellectual disability with onset before 18; prior experts and records support this | State: Childhood screening/test unreliable; no formal childhood diagnosis; evidence insufficient to prove pre-18 manifestation | Reversed and remanded — court must consider all three prongs together under Hall and Brumfield and fully weigh prior evidence |
| Whether circuit court properly required a childhood diagnosis or specific IQ test to prove onset before 18 | Oats: “Manifested” does not require a formal diagnosis or specific pre-18 Wechsler/Stanford-Binet test; circumstantial and school records suffice | State: Childhood Slosson screening insufficient; stricter proof needed | Held: Manifestation ≠ formal diagnosis; court erred by treating screening/test absence as dispositive |
| Whether the trial court abused discretion by failing to consider 1990 postconviction evidence | Oats: 1990 record contained extensive expert and lay evidence conceding low intelligence and childhood deficits; must be considered | State: Prior proceedings were different posture; relevance disputed | Held: Circuit court erred in refusing to weigh or recall 1990 evidence; that evidence must be considered or witnesses recalled |
| Standard for adjudicating intellectual disability post-Hall/Brumfield | Oats: Apply medical professional standards, consider prongs conjunctively, allow expert-informed assessment | State: Advocated for continued stricter scrutiny (as reflected in State expert testimony) | Held: Florida must follow Hall/Brumfield — use established medical practice, consider all three prongs interrelatedly, and not apply Cherry’s rigid 70 cutoff |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (2002) (Eighth Amendment prohibits execution of persons with intellectual disability; three-prong framework)
- Hall v. Florida, 134 S. Ct. 1986 (2014) (Florida’s strict IQ cutoff and refusal to account for test imprecision and medical standards violated the Eighth Amendment)
- Brumfield v. Cain, 135 S. Ct. 2269 (2015) (reinforced Hall; remanded for evidentiary hearing where childhood evidence supported manifestation and adaptive deficits)
- Cherry v. State, 959 So. 2d 702 (Fla. 2007) (prior Florida precedent applying a strict 70 IQ rule; disapproved by Hall)