mini brief
(Name Omitted)
Professor Hufford
Criminal Justice 100
9 October 2014
Mini-brief #2: Hall vs. Florida The United States Supreme Court heard the case Hall versus the state of Florida
on March 3, 2014. A decision was announced on May 27, 2014. The Supreme Court ruled in favor of an intellectually disabled death-row inmate, Freddie Lee Hall, and overturned a Florida court’s ruling that denied his appeal of the death penalty. This case addressed the fundamental rights contained in the Eighth Amendment to the United States Constitution. The eighth amendment protects U.S. citizens against excessive, or cruel and unusual punishment. The case also addressed the Fourteenth Amendment, which applied the rights outlined in the Eighth Amendment to the states. The ruling in this case will likely have implications on how punishment is determined in future cases where the defendant has intellectual deficits. This may especially be the case in the handful of states that had previously used very strict criteria to determine eligibility for the death penalty. In addition, writing for the majority, Justice Anthony Kennedy stated a desire to permanently remove the term “mental retardation” from legal proceedings and replace it with “intellectual disability.” The change in terminology is meant to reflect the way in which our society now views these disabled individuals.
Freddie Lee Hall’s legal team argued successfully in front of the Supreme Court that he should not be subjected to the death penalty. This is despite the fact that his IQ (testing between 71 and 80) is above the state of Florida’s rigid cut-off IQ score of 70.
Florida law heretofore had been rather strict in that regard, and would only allow those testing at 70 and below to present additional evidence of their intellectual disability. Evidence could include school and work records, as well as interviews with family members to prove that a defendant did not have the capacity to fully understand the implications of their actions. Previously, in a state such as Florida, if a defendant was unable to prove diminished capacity, he or she could be sentenced to death. By a majority ruling of 5-4, the United States Supreme Court declared this rigid standard to be unconstitutional. Justice Samuel Alito, who wrote the dissenting opinion, stated that the United States constitution leaves decisions about crime and punishment up to the individual states, not the federal government. He and the other three conservative members of the Supreme Court feel that it is up to the people of each state to determine how to establish eligibility for the death penalty, not a national organization of so-called experts. In fact, there are a number of states that do not even impose the death penalty at all. Therefore it should not be up to the federal government to set such standards.
The defendant, Freddie Lee Hall, along with an accomplice named Mark Ruffin, committed a series of horrific crimes. The pair kidnapped, raped and murdered a 21 year- old pregnant woman by the name of Karol Hurst in 1978. Following the murder, Hall and Ruffin proceeded to try to rob a grocery store and in the process, killed a police officer who had attempted to apprehend them. Hall was convicted and sentenced to death on the charge of murdering Karol Hurst. Charges of murdering the police officer were dropped as the county prosecutor felt that he could not show premeditation on the part of Mr. Hall. Hall’s defense team did not appeal the murder conviction. However, the death sentence was disputed, as they felt there was sufficient evidence to prove that Hall was mentally
disabled. He underwent a number of Wechsler IQ tests, and scored between 71 and 80. The lower court ruled that since his score was above 70, the defense team was not allowed to present any additional evidence demonstrating Mr. Hall’s disability. The death sentence was appealed to the Florida Supreme Court, who affirmed the ruling of the lower court.
Despite the appeals, the courts in Florida held strictly to the standards outlined in their state constitution, which established a strict cut-off level on IQ testing at 70. By 2014, most other states in the country no longer followed such a strict definition of intellectual disability. Only one other state had a similar cut-off using IQ testing as the sole standard to determine if a defendant is competent to stand trial and be subject to punishment. Most of the other states in our country had already relaxed the criteria for determining whether or not a defendant has an intellectual disability. For many states, this came in response to another important Supreme Court case from 2002. This most recent ruling by the United States Supreme Court will undoubtedly change this standard in Florida and the few other states forever.
The dilemma of whether an intellectually disabled person could face the death penalty as a consequence for their actions has been argued before the United States Supreme Court before. The majority opinion of Supreme Court in the Hall case cited a precedent from a 2002 case, Atkins versus the Commonwealth of Virginia. In Atkins, the Court decided that executing an intellectually disabled person constituted cruel and unusual punishment. In that case, the defendant Daryl Renard Atkins and an accomplice abducted, robbed, and subsequently murdered a man after withdrawing money from his bank account via an ATM machine in 1996. Between the video from the ATM machine
and the testimony of the codefendant in exchange for his avoidance of the death penalty, Atkins was convicted and subsequently sentenced to death. On appeal, Atkins’ defense team presented evidence that he had an IQ of 59, as well as significant functional difficulties. For this reason, they argued that he should not be subject to the death penalty. The case was appealed all the way up to the United States Supreme Court, where in a 6-3 majority opinion, the Virginia court ruling was overturned, and Atkins’ life was spared. Justice John Paul Stevens wrote the majority opinion and stated that the Eighth Amendment exists to respect the dignity of all persons. In so doing, it serves to protect an intellectually disabled defendant from the risk of wrongful execution. It is important to consider that someone intellectually disabled may be prone to give a false confession to police under the pressure of intense interrogation. They are also likely to be poor witnesses and have impaired ability to recall facts. Not to mention, intellectually disabled individuals may be unable to participate effectively in their own defense, making a trial less than fair.
It is important to note that both of these cases drew interest from people working in the mental health field; particularly those working with the intellectually disabled. The American Psychological Association filed an Amicus Brief on behalf of the two death row inmates, Hall and Atkins. This professional organization felt that it was important to advocate that standard IQ testing alone is a poor determinant of a person’s ability to be held responsible for their actions, and subsequently face punishment for their crimes. They maintained that the assessment of a person’s intellectual capacity should not he made just on the results of one type of test, and certainly not defined by an arbitrary number. An IQ score is at best just indicative of a range of mental function, and is not an
absolute definition. In other words, it takes more than IQ testing to determine whether somebody is capable of comprehending the implications of their actions. Sadly, the Florida statute would only allow other supporting information to be presented to the court if the defendants IQ was below 70, which hurt someone with borderline functioning like Mr. Hall. The current medical standard for the diagnosis of intellectual disability is that it must be evaluated comprehensively. This includes an assessment of social functioning skills as well as intellectual functioning. At best, the IQ test constitutes only one part of the overall assessment. Other information such as school records, work history, interviews with family are essential in order to fully determine a person’s intellectual capacity.
Overall, the Supreme Court ruling in the case of Hall verses Florida declared the state’s law enabling a rigid IQ standard to determine whether a defendant could be subject to the death penalty to be unconstitutional. The majority opinion expressed by Justice Kennedy reflects society’s current understanding of the complexity involved in assessing a person’s intellectual capacity, along with the desire to treat such persons with dignity and respect. Justice Kennedy went as far in his writing to express a desire to “permanently retire” the term “mental retardation” from legal proceedings. This ruling will have far reaching implications going forward, as it is likely to impact other convicts currently on death row who suffer from an intellectual deficit.
Works Cited: "Atkins v. Virginia 536 U.S. 304 (2002)." Justia Law. N.p., n.d. Web. 10 Oct. 2014.
<http://www.law.cornell.edu/supremecourt/text/12-10882>. "Hall v. Florida." http://www.apa.org. N.p., n.d. Web. 8 Oct. 2014.
<http://www.apa.org/about/offices/ogc/amicus/hall.aspx>. "SUPREME COURT OF THE UNITED STATES." supremecourt.gov. N.p., n.d. Web. 9
Oct. 2014. <http://www.supremecourt.gov/opinions/13pdf/12-10882_kkg1.pdf>.
"Supreme Court strikes down Florida law on intellectually disabled death row inmates." Washington Post. The Washington Post, n.d. Web. 10 Oct. 2014. <http://www.washingtonpost.com/politics/supreme-court-strikes-florida-law-on- intellectually-disabled-death-row-inmates/2014/05/27/45cda4f4-e5ab-11e3-8f90- 73e071f3d637_story.html>.