Intellectual Disability and the Death Penalty

Oats v. State, 181 So. 3d 457 (Fla. 2015), reh'g denied (Mar. 15, 2016)

Inability of defendant to show manifestation of intellectual disability before age 18 does not, alone, result in failure of Atkins claim; Hall v. Florida requires a court to analyze all three prongs of the intellectual disability diagnostic standard, and requires a different legal analysis of the onset prior to age 18 prong than was undertaken by the trial court.

Background: Sonny Boy Oats, Jr., was tried and convicted of robbery and first-degree murder in 1979 and his conviction was affirmed on appeal. In 1994, he sought postconviction relief but was denied. Post-Atkins, he filed a motion to vacate his death sentence on the grounds that he was intellectually disabled. The circuit court held an evidentiary hearing and denied the motion, concluding that Oats had not been able to establish that his intellectual disability had manifested prior to age 18 as required by Florida’s statutory test for determining intellectual disability.

Holding: The Florida Supreme Court reversed, giving three reasons for its decision. First, it noted that the Supreme Court’s decision in Hall v. Florida indicated that the lower court should have addressed all three prongs of the intellectual disability diagnostic standard and not denied the claim based on the apparent failure to meet one of the prongs. Second, the Court held that the lower court failed to consider all of the testimony presented, including evidence from prior postconviction proceedings. Third, the Court found that the lower court erroneously conflated “manifested” with “diagnosed,” an error upon which it based its conclusion that Oats failed to establish his intellectual disability.

Notable Points:

Hall v. Florida requires a circuit court to address all three prongs of the intellectual disability test rather than finding one factor to be dispositive: One of the three prongs of the intellectuality disability test is manifestation of the condition before age 18, but that determination is not dispositive. The Florida Supreme Court held that it was reversible error for the trial court not to consider all three prongs of the intellectual disability test, and to rely solely on the third prong of the test in denying Oats’s claim. The Court, however, was careful to say that, although this was reversible error here, failure to consider all three prongs should not constitute per se reversible error. Nonetheless, all three prongs must be considered because they are interdependent and, even when one is not satisfied, “a finding of intellectual disability may still be warranted based on the strength of the other prongs.”

The circuit court erred in making its conclusion without weighing all testimony presented by defendant: The Florida Supreme Court also held that it was error for the circuit court not to consider all the testimony that Oats presented. The parties stipulated to consideration of the mental health evidence presented in a previous proceeding, and the circuit court did not require the parties to recall all witnesses who testified previously. In its decision, however, the circuit court stated that it was “not in a position to reevaluate the credibility of the witnesses who testified or the evidence” considered in those prior proceedings and simply accepted the postconviction court’s ruling. The Florida Supreme Court held that the lower court should have permitted the parties to recall the witnesses in a new proceeding and submit evidence so that it could be considered and weighed.

Legal standard for analyzing whether intellectual disability manifested before age 18: The Florida Supreme Court noted that the manifestation prong is used to ensure there was evidence of intellectual disability during the developmental period, and that to require evidence of diagnosis before age 18 would render the first two prongs of the standard moot. The Court pointed to the U.S. Supreme Court’s analysis in Hall as demonstrative of how evidence of manifestation, without affirmative diagnosis, can lead to a clear finding that the prong was established.

Found in Found in DMHL Volume 35, Issue 1