Jermaine Foster v. State of Florida

Summary

The court affirmed the denial of Foster’s successive postconviction motion because his intellectual-disability claim depended on a retroactive application of Hall that current precedent foreclosed. The court declined to reconsider Phillips, held that Foster was procedurally barred from obtaining a Hall-based hearing, and concluded that the State’s earlier concession did not prevent it from renewing its legal argument. The court also held that summary denial was proper because Foster’s convictions and sentences were final before Hall.