Walls v. State
The Florida Supreme Court affirmed denial of capital defendant Frank Walls's successive postconviction motion seeking relief under Hall v. Florida on intellectual-disability grounds. The Court held that its intervening decision in Phillips v. State—which held Hall is not retroactive—forecloses Walls's claim regardless of the merits evidence presented at his evidentiary hearing, and rejected arguments to recede from Phillips or to apply Okafor/law-of-the-case doctrine to avoid that result.
Key facts
- Frank Walls was convicted and sentenced to death; his sentence became final before Hall v. Florida was decided in 2014.
- Walls filed a successive postconviction motion claiming intellectual disability and seeking relief under Hall v. Florida; the trial court held an evidentiary hearing on the claim.
- +2 more key facts with a free trial
Why it matters
This opinion reinforces that Phillips v. State definitively forecloses Hall-based intellectual-disability claims for capital defendants whose sentences became final before Hall was decided in 2014, even in cases… — full analysis with a trial
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