Juan David Rodriguez v. Mark S. Inch, Secretary, Florida Department of Corrections
DueProcess HabeasCorpus Punishment Securities JusticiabilityDoctri
Whether the disregard of medical and scientific consensus and well-established clinical authority when evaluating a claim of intellectual disability constitutes the impermissible denial of a capital defendant's substantive right to a reliable and accurate Atkins v. Virginia 536 U.S. 304 (2002), determination under the Eighth and Fourteenth Amendments
QUESTION PRESENTED This Court’s decisions in Hall v. Florida, 572 U.S. 701 (2014), Brumfield v. Cain, 576 U.S. 305 (2015), Moore v. Texas, 1387 S. Ct. 1039 (2017), and Moore v. Texas, 139 S. Ct. 666 (2019) (per curiam), reaffirmed the longstanding principle originally established in Atkins v. Virginia, 5386 U.S. 304 (2002), that States must be informed by the medical and scientific community’s diagnostic manuals and framework in determining whether an individual is intellectually disabled and thus ineligible for the death penalty under the Eighth Amendment. Mr. Rodriguez, who is an intellectually disabled prisoner on Florida’s death row, has sought relief pursuant to Atkins only to be repeatedly denied throughout his postconviction litigation in both state and federal court. In denying relief, both the state and federal courts have rejected Mr. Rodriguez's claims that he is ineligible for the death penalty under Atkins, based upon the determination that Mr. Rodriguez had failed to present evidence establishing that he possesses substandard intellectual functioning along with concurrent adaptive deficits as required under. § 921.137(1), Fla. Stat., and Fla. R. Crim. P. 3.203. The question presented is: Whether the disregard of medical and scientific consensus and well-established clinical authority when evaluating a claim of intellectual disability constitutes the impermissible denial of a capital defendant’s substantive right to a reliable and accurate Atkins v. Virginia 536 U.S. 304 (2002), determination under the Eighth and Fourteenth Amendments. i