Freddie Lee Hall v. State of Florida

Summary

The court affirmed the denial of Hall’s postconviction motion challenging his death sentence under Florida’s mental-retardation statute and rule. It held that Florida law requires an IQ score of 70 or below to establish the first element of mental retardation, does not incorporate a standard-error-of-measurement range, permits the inquiry to end when that element is not proven, and supported exclusion of an expert report lacking underlying data. Justice Pariente concurred based on existing statutory and precedential constraints, while Justices Labarga and Perry dissented because they would not apply the rigid cutoff where substantial evidence showed Hall had been mentally retarded throughout his life.