Hall v. Florida – Decision

Supreme_Court_US_2010In an opinion from 05/27/2014, the U.S. Supreme Court held that Florida’s 70-point threshold to determine intellectual disability in executions was unconstitutional. The majority opinion was delivered by Justice Kennedy in a split 5-4 decision. Justice Kennedy writes that the Florida statute used IQ scores as final and conclusive evidence of a defendant’s intellectual disability, even when experts consider other evidence. This rigid view of the score itself also refused to recognize the inherent imprecision in the IQ measurement. Justice Kennedy notes that both of these factors disregard established medical practice, which defines intellectual disability as the existence of concurrent deficits in intellectual and adaptive functioning.

Justice Kennedy reports that in 41 other states, Mr. Hall’s position would not be deemed automatically eligible for the death penalty. Justice Kennedy concludes that when an individual’s IQ falls within the margin of error (as it does in Mr. Hall’s case), “the individual must be able to present additional evidence of intellectual disability, including testimony regarding adaptive deficits.”

In the dissent section of the opinion, Justice Alito writes that the “Eighth Amendment prohibits a death sentence for defendants who are intellectually disabled, but does not mandate the use of a single method for identifying such defendants.” Justice Alito goes on to note that the Court’s reliance on the views of professional associations will lead to serious practical problems, due to the views of professional associations often changing. Justice Alito provides the example that the diagnostic criteria for intellectual disability are markedly different than were previously cited in the case of Atkins v. Virginia.

Both the majority opinion and the dissent may have applications to forensic psychiatry. The majority opinion emphasizes that intellectual disability is marked by deficits in both intellectual and adaptive functioning, reflecting both Criterion A and Criterion B for this diagnosis in the DSM-5. The dissent opinion seems to caution, though, that pitfalls may exist when changing diagnostic criteria affect the interpretation of legal standards.

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