Supreme Court of Florida

Kenneth Darcell Quince v. State of Florida

January 18, 2018

Summary

The court affirmed the denial of Quince's renewed motion to establish intellectual disability as a bar to execution. It held that the governing framework did not require adjusting his IQ scores for the Flynn effect, and competent, substantial evidence supported refusing to do so. Because Quince failed to satisfy the significantly subaverage intellectual functioning prong even under a preponderance standard, the court declined to decide whether the statutory clear-and-convincing-evidence burden was constitutional.