Harry Franklin Phillips v. State of Florida

Summary

The court affirmed the denial of Phillips’s successive postconviction motion, holding that the constitutional rule requiring consideration of the standard error of measurement for IQ scores does not apply retroactively to cases on collateral review. The court concluded that the rule is procedural and an evolutionary refinement rather than a development of fundamental significance, and it therefore receded from its prior decision treating the rule as retroactive. The court declined to reach Phillips’s alternative adaptive-deficits claim because he had conclusively failed to establish the intellectual-functioning prong.