## Facts

- Freddie Lee Hall was convicted in Florida of murdering a pregnant woman and a deputy sheriff and was sentenced to death.
- At a resentencing, Hall presented substantial evidence of intellectual disability (school records, psychological evaluations, and lay testimony); the sentencing court acknowledged substantial evidence of lifelong intellectual disability but again imposed death.
- After *Atkins v. Virginia* held the Eighth Amendment prohibits executing persons with intellectual disability, Hall sought to vacate his death sentence on that basis.
- Florida’s courts applied a rule requiring an IQ score of 70 or below as a prerequisite to any consideration of other intellectual-disability evidence, including adaptive-functioning deficits.
- Hall’s IQ score at his *Atkins* proceeding was 71, and Florida courts held this foreclosed any further inquiry into intellectual disability.

## Issues

1. Whether the Eighth Amendment permits a state to bar a defendant with an IQ score above 70 from presenting additional evidence of intellectual disability, including adaptive-functioning deficits, to avoid a death sentence.
2. Whether a rigid IQ cutoff that ignores the standard error of measurement creates an unconstitutional risk of executing persons with intellectual disability.

## Decision

- The Supreme Court reversed the Florida Supreme Court.
- The Court held Florida’s rigid IQ-70 cutoff, treated as conclusive and applied without accounting for measurement error, violates the Eighth Amendment.
- The Court required that when an IQ score falls within the test’s margin of error around 70, the defendant must be allowed to present additional evidence of intellectual disability, including adaptive-functioning deficits and developmental history.

## Legal Principles

- The Eighth Amendment categorically prohibits execution of persons with intellectual disability, and state procedures must meaningfully enforce that protection.
- IQ scores must be interpreted in light of the standard error of measurement; an IQ score is evidence of a range rather than a fixed value.
- When the score is within the margin of error near the eligibility threshold, a state must permit consideration of other clinical indicators of intellectual disability, including adaptive deficits and onset before age 18.
- A state rule that treats an IQ score as final and conclusive, foreclosing further evidence, creates an unacceptable risk of executing persons the Constitution protects from capital punishment.

## Conclusion

The Court invalidated Florida’s strict IQ-70 cutoff for capital intellectual-disability determinations, holding that the Eighth Amendment requires accounting for IQ test measurement error and allowing defendants with borderline scores to present adaptive-functioning and related evidence before they may be deemed eligible for execution.


Hall v. Florida, 572 U.S. 701 (2014)