David Beasher Snelgrove, Appellant v. State of Florida, Appellee — Pariente, J., Concurring in Part and Dissenting…

Summary

Pariente, J. concurs that Snelgrove is entitled to relief under Hurst but dissents from the majority’s conclusion that the defendant is not entitled to post‑conviction relief on his claim of intellectual disability. He argues that the 2009 hearing occurred before Hall v. Florida and therefore a new evidentiary hearing is required to apply Hall’s conjunctive assessment of the three prongs. The opinion emphasizes that the bright‑line IQ cutoff of 70 has been disapproved and that a holistic analysis is now mandatory. Justice POLSTON, dissenting in part, concurs except for the majority’s vacating of the death sentences.