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Supreme Court Issues Opinions on Use of IQ Test Score in Death Cases; Double Jeopardy; and Use of Deadly Force in High Speed Chases

Today, the Supreme Court decided Hall v. Florida (No. 12-10882), Martinez v. Illinois (No. 13-5967), and Plumhoff v. Rickard (No. 12–1117).
  
In Hall v. Florida, the Court held that 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.  Writing for the 5-4 majority, Justice Kennedy explained:

"This Court has held that the Eighth and Fourteenth Amendments to the Constitution forbid the execution of persons with intellectual disability. Atkins v. Virginia, 536 U.S. 304 , 321 (2002). Florida law defines intellectual disability to require an IQ test score of 70 or less. If, from test scores, a prisoner is deemed to have an IQ above 70, all further exploration of intellectual disability is foreclosed. This rigid rule, the Court now holds, creates an unacceptable risk that persons with intellectual disability will be executed, and thus is unconstitutional."

For more on the opinion see this SCOTUSblog post.

The Court issued a per curiam opinion in Martinez v. Illinois, addressing a double jeopardy claim. The Court held that where the trial court had granted Martinez's motion for a directed not-guilty verdict after the court swore in the jury and the State declined to present any evidence, the State could not then appeal in an attempt to subject Martinez to a new trial.  For more on the case, see this SCOTUSblog post.

In Plumhoff v. Rickard, a qualified immunity case, the Court held that the use of deadly force by police officers (firing multiple rounds into a car during a high-speed chase, contributing to the death of the driver and a passenger) was not unreasonable given the threat to public safety. As such, the officers did not violate the Fourth Amendment and, in any event, the officers were entitled to qualified immunity because they did not violate any clearly established law.  For more on the case, see this SCOTUSblog post.
 

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