Sliney v. State
The Florida Supreme Court affirmed summary denial of a second successive postconviction motion in which a death-row inmate argued the Eighth Amendment should categorically bar execution of offenders aged 18-21, relying on a 2021 AAIDD manual raising the age of onset for intellectual disability diagnosis to 22. The Court held the claim was untimely because the manual did not present newly discovered 'facts' distinct from long-available brain-development science, and reaffirmed that Roper's 18-year-old line remains the controlling rule absent a U.S. Supreme Court extension.
Key facts
- Death-row inmate Sliney sought a second successive postconviction motion arguing the Eighth Amendment should categorically bar execution of offenders aged 18-21, relying on a 2021 American Association on Intellectual and Developmental Disabilities manual that raised the age of onset for intellectual disability diagnosis to 22.
- The trial court summarily denied the motion without an evidentiary hearing, and Sliney appealed.
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Why it matters
This opinion is useful to capital postconviction practitioners confronting recurring attempts to extend Roper v. Simmons to young adult offenders via successive 3.851 motions. It sharpens the facts-versus-evidence… — full analysis with a trial
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