Whether Florida violated Atkins v. Virginia, Hall v. Florida, Moore v. Texas, and the Eighth and Fourteenth Amendments by disregarding medical evidence in finding Kenneth Darcell Quince intellectually capable of execution

QUESTIONS PRESENTED , QUESTION ONE , Did Florida violate Atkins v. Virginia, Hall v. Florida, Moore v. Texas, and the Eighth and Fourteenth Amendments of the United States Constitution when it disregarded the opinion(s) of the medical community in accepting the Flynn effect as a valid correction of intelligence quotient scores formulated from outdated tests, and further disregarded the medical diagnostic framework for intellectual disability by ignoring the evidence of deficits in adaptive functioning manifested prior to the age of 18, thus finding Kenneth Darcell Quince eligible to be executed? ; QUESTION Two Whether Florida’s statutory mandate that Kenneth Darcell Quince prove all three prongs to ‘ determine intellectual disability by clear and convincing evidence creates a real danger of executing the intellectually disabled in violation of Atkins v. Virginia, Cooper v. Oklahoma, Medina y. California, and the Eighth and Fourteenth Amendments to the United States Constitution? : i