Woodall v. Commonwealth
563 S.W.3d 1
| Mo. Ct. App. | 2018Background
- Robert Keith Woodall pleaded guilty to murder, rape, and kidnapping; a jury recommended death and the trial court imposed it.
- Nearly 20 years later Woodall filed post-conviction motions under CR 60.02/60.03 claiming he is intellectually disabled and thus ineligible for execution; he requested expert funding and obtained an expert opinion supporting disability.
- The trial court denied Woodall’s motion without an evidentiary hearing; Woodall appealed to the Kentucky Supreme Court seeking a hearing or a final determination of intellectual disability.
- The case required the Court to consider whether Kentucky’s statute KRS 532.130(2), which sets a bright-line IQ cutoff (70) for “significantly subaverage intellectual functioning,” comported with the Eighth Amendment as interpreted by the U.S. Supreme Court.
- The Commonwealth conceded a hearing was necessary; the Kentucky Supreme Court reviewed U.S. Supreme Court decisions (Atkins, Hall, Moore) and its own prior precedents (Bowling, White) to decide whether the statute and trial-court procedure were constitutional.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether KRS 532.130(2)’s bright-line IQ cutoff (IQ ≤70) is constitutional under the Eighth Amendment | Woodall: Rigid numerical cutoff can bar consideration of other medical evidence and thus violates Atkins/Hall/Moore; prevailing medical standards must govern | Commonwealth: Kentucky’s statute and prior practice (adjusting for SEM) are permissible; courts can and should apply statutory cutoff and then hold hearings when warranted | Court: KRS 532.130(2) is unconstitutional insofar as it forecloses consideration of prevailing medical standards and other evidence when IQ >70 (after SEM); IQ alone cannot be dispositive |
| Appropriate remedy / procedure when intellectual disability is claimed post-conviction | Woodall: Court should find him intellectually disabled or grant hearing under correct standard | Commonwealth: Agreed a hearing is needed; urged adherence to statutory process or trial-level resolution | Court: Reverse trial court; remand for an evidentiary hearing applying U.S. Supreme Court guidance (Moore/Hall) and prevailing medical standards; defendant bears burden by preponderance but may present full medical evidence |
Key Cases Cited
- Atkins v. Virginia, 536 U.S. 304 (bar on executing intellectually disabled persons)
- Hall v. Florida, 572 U.S. 701 (invalidating rigid IQ cutoff and requiring courts to consider additional evidence and medical standards)
- Moore v. Texas, 137 S. Ct. 1039 (reaffirming that determinations must be informed by prevailing medical standards; courts may not substitute their own lay stereotypes)
- Bowling v. Commonwealth, 163 S.W.3d 361 (Ky. 2005) (prior Kentucky interpretation endorsing statutory 70 IQ ceiling)
- White v. Commonwealth, 500 S.W.3d 208 (Ky. 2016) (Kentucky guidance requiring consideration of standard error and additional evidence once evaluation ordered)