May 27, 2014
APA's Statement Regarding SCOTUS Ruling in Hall v. Florida
WASHINGTON — The American Psychological Association applauded the U.S. Supreme Court today for vacating the death sentence for a mentally disabled Florida man.
APA filed a friend-of-the-court brief in the case, Hall v. Florida, advising that there is unanimous professional consensus that the diagnosis of intellectual disability requires comprehensive assessment and the application of clinical judgment as opposed to basing the determination solely on a fixed score on an intelligence test. The defendant, Freddie Lee Hall, had been sentenced to death because under Florida law, his IQ test score of 71 — one point higher than the automatic cutoff point of 70 used by Florida — barred him from showing that he was intellectually disabled and therefore ineligible for the death penalty.
“We are pleased that the majority of the court agreed that Florida’s use of a fixed IQ score cutoff to determine a defendant’s intellectual functioning is based on a fundamental misunderstanding of how to interpret IQ tests,” said Nathalie Gilfoyle, JD, APA’s general counsel. “The court agreed with the uniform scientific consensus across professional organizations with expertise in testing that intellectual disability cannot be accurately diagnosed without an evaluation of an individual’s adaptive functioning in conjunction with his or her general intellectual functioning and age of onset.”
APA’s brief also underscored a key point relied upon by the court in its ruling — that IQ test scores used to diagnose limitations in intellectual functioning are subject to a standard error of measurement, and that the interpretation of those scores must take that factor into account. Specifically, APA explained that any IQ test score is subject to an error rate of plus or minus 5 points. Thus Hall’s score of 71 could reflect an IQ of as low as 66. The court relied on the professional consensus reflected in APA’s brief in reaching its conclusion that barring consideration of a defense of intellectual disability in a death penalty case based on a failure to meet a strict IQ score cutoff of 70 violates the Constitution.
APA was joined on its brief by the American Psychiatric Association; the American Academy of Psychiatry and the Law; the Florida Psychological Association; the National Association of Social Workers; and NASW’s Florida Chapter.
The American Psychological Association, in Washington, D.C., is the largest scientific and professional organization representing psychology in the United States. APA's membership includes nearly 130,000 researchers, educators, clinicians, consultants and students. Through its divisions in 54 subfields of psychology and affiliations with 60 state, territorial and Canadian provincial associations, APA works to advance the creation, communication and application of psychological knowledge to benefit society and improve people's lives.
Kim I. Mills