Freddie Lee Hall, Appellant v. State of Florida, Appellee

Summary

On remand, the court held that Hall established intellectual disability under the clinical, statutory, and constitutional standards applicable to capital sentencing. It rejected a rigid IQ cutoff, permitted retrospective evidence of adaptive functioning, and held that developmental onset could be shown without a specific childhood IQ test. The court reversed the denial of postconviction relief, vacated the death sentence, and remanded for imposition of a life sentence. Justice Canady, dissenting and joined by Justice Polston, would have ordered a new adversarial evidentiary hearing rather than resolving the claim on appeal.