Supreme Court of Florida

Sonny Boy Oats, Jr., Appellant v. State of Florida, Appellee

December 17, 201540 Fla. L. Weekly Supp. 705

Summary

The court reversed the denial of Oats's motion challenging his death sentence based on intellectual disability and remanded for a complete reevaluation. It held that the lower court improperly treated pre-age-eighteen manifestation as dispositive, failed to consider and weigh all relevant evidence, and equated manifestation with childhood diagnosis. The court directed that the evaluation apply contemporary medical standards and consider all three intellectual-disability prongs together.