Jermaine Foster, Appellant v. State of Florida, Appellee.

Summary

The court held that Foster was entitled to an evidentiary hearing on his intellectual-disability claim because his earlier proceedings occurred before the governing standards required consideration of IQ-score measurement error and a holistic assessment of all three prongs. The court also held that Foster was not entitled to relief on his capital-sentencing claims because the sentences became final before the applicable constitutional rule was made retroactive. Justice Pariente concurred in the result but would have relied on the unanimous death recommendations and other sentencing facts rather than finality; Chief Justice Canady, joined by Justice Polston, would have affirmed the denial of the intellectual-disability claim and rejected the sentencing claims on additional grounds.