Foster v. State
The Florida Supreme Court affirmed denial of a successive postconviction motion in a capital case, holding that under Phillips v. State and Thompson v. State, Hall v. Florida does not apply retroactively to intellectual-disability claims for defendants whose sentences were already final, foreclosing Foster's claim despite an earlier remand for a Hall-compliant hearing. The Court also held that the State's earlier concession—made in reliance on then-controlling Okafor—that it could not deviate from the mandate requiring a hearing, did not bind the postconviction court once Thompson clarified and limited Okafor's application, because stipulations/concessions on questions of law are not binding.
Key facts
- Foster, a capital defendant whose death sentence was final before Hall v. Florida was decided, filed a successive postconviction motion claiming intellectual disability based on Hall's more lenient standard.
- The trial court had previously granted Foster a Hall-compliant hearing on remand after the State conceded it could not deviate from the mandate requiring such a hearing under then-controlling Okafor precedent.
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Why it matters
This opinion reinforces the now-settled rule that Hall v. Florida's more lenient intellectual-disability standard does not retroactively benefit defendants whose death sentences were final before Hall was decided… — full analysis with a trial
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