Frank A. Walls, Appellant v. State of Florida, Appellee — Canady, J., Dissenting

Summary

Justice Canady dissents, arguing that the trial court’s denial of Walls’ intellectual‑disability claim should be affirmed because Walls failed to show juvenile onset, the majority misinterprets Hall v. Florida, and Hall should not apply retroactively. The dissent contends the majority’s errors undermine the proper application of the statutory three‑prong test and the retroactivity analysis. It maintains that Walls’ IQ scores of 102 and 101 as a juvenile preclude meeting the onset requirement, and that Hall does not alter that requirement. The opinion notes a concurring opinion that reaches the opposite conclusion regarding retroactivity.