Supreme Court Strikes Down I.Q. Requirement in Death Penalty Case
In 2002 the U.S. Supreme Court held the execution of "mentally retarded criminals" to be unconstitutional under the Eighth Amendment. Today, by a vote of 5-4, the Court extended that ruling to invalidate a Florida statute governing the use of I.Q. tests in death penalty cases.
At issue today in Hall v. Florida was an appeal filed by a convicted murderer named Freddie Lee Hall, who maintains that his capital sentence is illegitimate under that 2002 precedent due to his intellectual disability. As evidence of this disability, Hall presented state officials with test results showing his I.Q. score to be 71. Under Florida law, however, Hall must, as a threshold matter, score 70 or less on an I.Q. test before any further consideration may be given to his intellectual disability case.
Writing today for the majority, Justice Anthony Kennedy struck down what he called Florida's "rigid rule" because it deprived Hall and others like him of a "fair opportunity to show that the Constitution prohibits their execution." According to the Court, "Freddie Lee Hall may or may not be intellectually disabled, but the law requires that he have the opportunity to present evidence of his intellectual disability, including deficits in adaptive functioning over his lifetime."
Writing in dissent, Justice Samuel Alito, joined by Chief Justice John Roberts and Justices Antonin Scalia and Clarence Thomas, criticized Kennedy for "strik[ing] down a state law based on the evolving standards of professional societies, most notably the American Psychiatric Association," rather than respecting the judgment of Florida lawmakers. "Under our modern Eighth Amendment cases," Alito argued, "what counts are our society's standards—which is to say, the standards of the American people—not the standards of professional associations, which at best represent the views of a small professional elite."
Kennedy, by contrast, had the following to say about the deference due to the I.Q. threshold set by Florida officials: "The States are laboratories for experimentation, but those experiments may not deny the basic dignity the Constitution protects."
The Court's opinion in Hall v. Florida is available here.
