The Florida Supreme Court ruled September 8 that Freddie Lee Hall is not eligible for the death penalty, concluding a long running saga that led to the Supreme Court redefining the bounds of the constitutionality of the death penalty against people with intellectual disabilities.
“We are pleased to see justice finally being served. Our hope is that Florida’s decision will serve as guidepost to other states that have similar cases involving defendants with intellectual disability,” Peter Berns, CEO of the Arc, wrote in a blog post. “While we are pleased with Florida’s decision, we also think of other individuals who were unjustly denied Atkins protections and sentenced to death, individuals like Warren Hill, executed in Georgia last year, despite the protections of the Atkins decision.”
The Supreme Court ruled in 2002 that the Eighth Amendment bars the use of the death penalty against people with intellectual disabilities. Until 2014, however, states had complete discretion to define intellectual disability for the purposes of complying with this mandate.
That year, the Supreme Court reviewed the death sentence issued by Florida for Hall, convicted of the 1978 murder of a 21-year-old pregnant woman. At the time, the state’s capital punishment regime used a strict 70-IQ cutoff.
The Supreme Court struck down the statute, remanding Hall’s case back to the Florida Supreme Court. Specifically, the 5-4 majority ruled that Florida’s law was unconstitutionally narrow, finding that states must also consider a person’s adaptive functioning, in addition to their IQ, when measuring intellectual disability.
The Florida Supreme Court heard extensive testimony in the case, documenting his troubled childhood and extensive shortcoming at every educational level. The court heard from family members and mental health professionals, establishing a far more extensive record of the extent of Hall’s disabilities.
“After careful consideration of the parties’ briefs, the voluminous record, and the United States Supreme Court’s decision, we withdraw our prior opinion and conclude that Hall has demonstrated that he meets the clinical, statutory, and constitutional requirements to establish that his intellectual disability serves as a bar to execution,” the Court wrote in a 23-page ruling [PDF].
As such, Hall’s sentence is now life in prison without parole.