Hall v. Florida
Question: Is it a violation of the Eighth Amendment to execute those with borderline intellectual functioning?
Holding: Florida’s threshold requirement, as interpreted by the Florida Supreme Court, that defendants show an IQ test score of 70 or below before being permitted to submit additional intellectual disability evidence is unconstitutional because it creates an unacceptable risk that persons with intellectual disabilities will be executed. The Court prohibited states from relying only on intelligence test scores to determine whether a defendant can be executed in borderline IQ cases. IQ tests have a margin of error, and those inmates whose scores fall within the margin must be allowed to present other evidence of mental disability.
Moore v. Texas (2019)
Question: Did the Texas Court of Criminal Appeals err in holding that the defendant did not have an intellectual disability and was eligible for the death penalty?
Holding: Yes; SCOTUS reversed the lower court finding. In its original decision in 2017, the Court criticized the lower court for basing its analysis and reasoning on outdated medical standards. They noted the appeals court’s opinion rested on an analysis that too closely resembled what they previously found to be improper (e.g., the court focused on adaptive strengths rather than adaptive deficits, and used Texas’ outdated Briseno factors).