The U.S. Supreme Court ruled today that the state of Florida cannot execute death row inmate Freddie Lee Hall based solely on his IQ test score.
In line with amicus briefs written by a bevy of professional mental health organizations, the court ruled that Hall and his lawyers must be allowed to present additional evidence of his intellectual disability before state officials can decide if he can be put to death. The decision reins in a state’s power to determine who is mentally competent enough to qualify for the death penalty.
In 2002, the high court barred the execution of people who are intellectually disabled as cruel and unusual punishment, but left it up to states to define who is impaired. Florida adopted one of the strictest definitions of intellectual disability—an IQ score of 70 or below—and barred anyone with a higher score from presenting additional evidence of their impaired function.
Hall, now 68, was sentenced to death in 1978 for his role in the rape and murder of a pregnant, 21-year-old woman. He scored 71 points on his most recent IQ test and has scored higher and lower in previous assessments. In a 5 to 4 decision, the Supreme Court found that Florida had ignored the current scientific consensus about how to diagnose mental disability and violated Hall’s constitutional right to present further evidence supporting his mental status, such as school and medical records.
"Freddie Lee Hall may or may not be intellectually disabled, but the law requires that he have the opportunity to present evidence of his intellectual disability, including deficits in adaptive functioning over his lifetime," Justice Anthony Kennedy wrote for the majority in the case, Hall v. Florida.
The ruling corrects a “fundamental misunderstanding of how to interpret IQ tests," said Nathalie Gilfoyle, the American Psychological Association's (APA’s) general counsel, in a press release. She added, “The uniform scientific consensus across professional organizations is that intellectual disability cannot be accurately diagnosed without more comprehensive evaluation of an individual's ability to reason, adapt, and function in real life over the course of their lives.” The decision also acknowledges that Hall's assessment did not include the standard 5-point margin of error built into the design of the test, she noted.
Justices Samuel Alito, John Roberts, Antonin Scalia, and Clarence Thomas dissented, arguing that medical and scientific organizations such as APA should not play such a large role in determining what constitutes intellectual disability. What counts in such situations are not the views of a “small professional elite,” but “our society's standards—which is to say, the standards of the American people,” Alito wrote.