FREDDIE LEE HALL v. FLORIDA
Supreme Court of the United States, Kennedy, Filed May 27, 2014,
Capital Punishment- It is a violation of the 8th Amendment to impose the death penalty on a person whose IQ test score is above 70, including a score within the margin for measurement error, while barring them from presenting other evidence that would show his faculties are limited.
“Intellectual disability is a condition, not a number.”
This line from Hall v. Florida pretty much sums up the opinion, which I won’t dissect in detail because it so painfully demonstrates how the adversarial appellate process eschews fact-finding in favor of citation to “authority” (in this instance, not remanding for fact-finding on the appropriateness of the IQ exam, but rather conducting its own “peer review” and synthesis of material in which it has no explicit expertise). That is not to say that the result arrived at was incorrect, but rather that the method used to arrive at that result was flawed.
Notes from the USSC on the 8th Amendment:
– The Eighth Amendment “is not fastened to the obsolete but may acquire meaning as public opinion becomes enlightened by a humane justice.”
– To enforce the Constitution’s protection of human dignity, this Court looks to the “evolving standards of decency that mark the progress of a maturing society.”
– The Eighth Amendment does not allow persons with intellectual disability to be executed
– This is not to say that under current law persons with intellectual disability who “meet the law’s requirements for criminal responsibility” may not be tried
and punished. They may not, however, receive the law’s most severe sentence.