Supreme Court of Florida

Frank A. Walls v. State of Florida – Corrected Opinion

May 4, 2017

Summary

The court held that the constitutional rule governing intellectual-disability determinations applies retroactively and that Walls was entitled to a new evidentiary hearing. His prior hearing used an unconstitutional rigid IQ cutoff and therefore did not provide the holistic, interrelated assessment required by current law. The court reversed the summary denial and remanded for a new hearing under the appropriate standards.