Law Commons^™

Hall V. Florida: The Supreme Court's Guidance In Implementing Atkins, James W. Ellis

Faculty Scholarship

In Atkins v. Virginia, the U.S. Supreme Court concluded that criminal defendants with mental retardation could not be sentenced to death or be executed because such an execution would constitute cruel and unusual punishment and therefore was prohibited by the Eighth Amendment. A dozen years later, in Hall v. Florida, the Court has reiterated the constitutional holding of Atkins and has given the states guidance on its implementation. The Court held that Florida could not impose an arbitrary IQ score limitation on the right of capital defendants to seek relief under Atkins. While the holding in Hall was relatively narrow, …