Hall v. Florida
October 21, 2013
Case #: 12-10882
109 So. 3d 704 (Fla. 2012)
Full Text Opinion: http://scholar.google.com/scholar_case?case=17658209165662130573&hl=en&as_sdt=6,38
Constitutional Law: Whether the Florida scheme for identifying mentally retarded defendants in capital cases violates Atkins v. Virginia.
Petitioner was convicted of murder and sentenced to death. Following the ruling in Atkins v. Virginia, Petitioner filed a motion to declare a Florida statute, §921.137, unconstitutional. The lower court held that Petitioner did not meet the first prong of their mental retardation standard which required an IQ below 70 and the court denied relief.
Petitioner appealed and argued (1) that the trial court’s finding that Petitioner was not mentally retarded was not supported by competent, substantial evidence; (2) that the trial court erred in granting the State’s motion in limine that limited the evidence Petitioner could present on his mental retardation claim; (3) that the trial court erred by striking the Doctor's report; and (4) that the trial court should have imposed a life sentence based on the doctrine of collateral estoppel.
On appeal the court affirmed and held that there was competent, substantial evidence to support the lower court’s findings that Petitioner was not mentally retarded. Under Atkins v. Virginia, the power to enforce constitutional restrictions of the death penalty on the mentally handicapped is left to the states. The Supreme Court granted certiorari to decide whether the Florida scheme for identifying mentally retarded defendants in capital cases violates Atkins v. Virginia.