Hall v.

Florida

Facts

Freddie Lee Hall was charged and convicted for the murder of Karol Hurst. Hall was
sentenced to death. He sought a writ of habeas corpus and a stay of execution in state court, but
he was denied. Hall then sought a writ of habeas corpus in federal court, which was also denied.
He appealed to the U.S. Court of Appeals for the Eleventh Circuit, where they remanded the case
for a hearing despite the possibility Hall would be absent from the courtroom during the trial and
his ineffective counsel. The District Court again denied Hall habeas corpus. They held that Halls
absences from the courtroom were harmless and that he bypassed ineffective counsel claims. The
Court of Appeals affirmed.
Hall petitioned the Supreme Court of Florida for habeas corpus relief based on a previous
Supreme Court decision. Hitchcock v. Dugger held that all mitigating factors should be
considered rather than just those listed in the relevant statutes. The Supreme Court of Florida
denied the petition and held that no error occurred. The governor signed his death warrant. Hall
then filed a motion to vacate the sentence. The trial court denied this motion due to the fact that
the Supreme Court of Floridas decision prevented any further review of the case. The Supreme
Court of Florida disagreed and found that the case involved other non-record facts that had not
been considered in the previous review. The case was remanded for a new sentencing. At the
new sentencing trial, the court found that Halls mental retardation was a mitigating factor with
unquantifiable weight, and was again sentenced to death. The Supreme Court of Florida
affirmed.
In a precedent case, Atkins v. Virginia, the Supreme Court found that the execution of
mentally retarded defendants violated the Eighth Amendment protection against cruel and
unusual punishment. Based on this case, Hall filed a motion to declare certain sections of the
Florida death penalty statute unconstitutional. He filed a claim to be exempt from the death
penalty due to his mental retardation and based it on this precedent. The trial court held that Hall
was not eligible for such a claim. The Supreme Court of Florida affirmed.

Issue

Does the Florida scheme for identifying mentally retarded defendants in capital punishment
cases violate the standards established in Atkins v. Virginia?

Judicial Decision and Reasoning

The Supreme Court came to a 5-4 decision in favor of Hall. They found that executing an
intellectually disabled person does violate the Eighth Amendments protection against cruel and
unusual punishment. The death penalty serves no legitimate purpose when a person is not able to
make proper judgments due to mental retardation.

Analysis

This case is important because it enforces that an intellectually retarded or disabled

person may not be executed. This will serve as a very significant precedent to other cases that
deal with mentally disabled defendants.