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The U.S. Supreme Court, Second Edition

Hall v. Florida

by Thomas Tandy Lewis

Citation: 572 U.S. ___

Announced: May 27, 2014

Issues: Capital punishment; Diminished responsibility

Significance: The Supreme Court held that when states punish persons with intellectual disabilities, all relevant factors—not an I.Q. score alone—must be taken into account.

In Atkins v. Virginia (2002), the Supreme Court ruled that disabled persons were ineligible for the death penalty if they met a three-prong standard: (1) a sub-average I.Q. test score; (2) a lack of basic social and practical skills; and (3) the presence of both conditions before the age of 18. The Court said that I.Q scores of approximately 70 or below generally indicated disability but let the states make specific rules about who was mentally disabled. Based on this flexibility, Florida passed a statute disallowing state courts to consider evidence of a person’s disability unless his I.Q. score was 70 or lower. The Florida trial court refused to consider Freddie Lee Hall’s claim of disability, because his test scores were between 71 and 80. Hall’s lawyers petitioned the Florida Supreme Court for habeas corpus relief, pointing out that the U.S. Supreme Court in Hitchcock v. Dugger (1978) had required that all mitigating factors be considered, not simply those mentioned in relevant statutes. When his petition was rejected, Hall’s lawyers appealed to the U.S. Supreme Court, claiming a constitutional violation.

In a 5-4 decision, the Court ruled in favor of Hall’s position and held that Florida’s method for identifying mental disability did not conform to the binding precedents enunciated in Hitchcock and Atkins. Delivering the opinion for the Court, Justice Anthony Kennedy argued that the “rigid rule” of the Florida statute “creates an unacceptable risk that persons with an intellectual disability will be executed, and thus is unconstitutional.” Since I.Q. tests are not infallible, other sources of information must also be taken into account. Referring to the American Psychiatric Association’s’ Diagnostic and Statistical Manual of Mental Disorders (DSM-5), Kennedy wrote that the Court “agrees with medical experts that when a defendant’s IQ test score falls within the test’s acknowledged and inherent margin of error, the defendant must be able to present additional evidence of intellectual disability, including testimony regarding adaptive deficits.”

In a dissent, Justice Samuel Alito argued that the majority opinion was an unprecedented departure from the Court’s Eighth Amendment jurisdiction, because it relied on professional standards instead of the evolving standards of society at large. The majority’s prescribed method for evaluating intellectual ability was highly subjective, and there was no good evidence that it was any more accurate than I.Q. tests alone. Alito also asserted that the standards of professional psychological and psychiatric organizations frequently change; basing Eighth Amendment jurisprudence on their questionable conclusions would likely result in instability and protracted litigation.

The Hall decision struck down relevant portions of nine state statutes as inconsistent with the proscription against Cruel and Unusual Punishments of the Eighth Amendment.

See also

Capital punishment; Eighth Amendment; Atkins v. Virginia.

Citation Types

Type
Format
MLA 9th
Lewis, Thomas Tandy. "Hall V. Florida." The U.S. Supreme Court, Second Edition, edited by Thomas Tandy Lewis, Salem Press, 2016. Salem Online, online.salempress.com/articleDetails.do?articleName=SC2E_0240.
APA 7th
Lewis, T. T. (2016). Hall v. Florida. In T. Lewis (Ed.), The U.S. Supreme Court, Second Edition. Salem Press. online.salempress.com.
CMOS 17th
Lewis, Thomas Tandy. "Hall V. Florida." Edited by Thomas Tandy Lewis. The U.S. Supreme Court, Second Edition. Hackensack: Salem Press, 2016. Accessed December 14, 2025. online.salempress.com.