Whether Hall's holding that the 3-pronged test for assessing intellectual disability must be informed by prevailing medical practice and standards announced a new rule of constitutional law

QUESTIONS PRESENTED In Atkins v. Virginia, 536 U.S. 304 (2002), this Court held that the Eighth and Fourteenth Amendments preclude the execution of individuals with intellectual disability but left to the states the task of developing a mechanism to determine who falls within that category. In response to this directive, the Florida Supreme Court limited Atkins’s reach by imposing strict rules for establishing intellectual disability that this Court, in Hall v. Florida, 572 U.S. 701 (2014), later repudiated. In Hall, this Court found that the Florida Supreme Court had interpreted the state’s statute in a manner that precluded courts from considering current medical practices and standards in evaluating the 3-pronged test for intellectual disability, in violation of the Eighth Amendment. Specifically, with regard to the adaptive functioning assessment, this Court made clear that such a determination, like the first prong, was to be informed by prevailing medical standards and practice. In Walls v. State, 213 So. 3d 340 (Fla. 2016), the Florida Supreme Court held that this Court’s decision in Hall applied retroactively in collateral proceedings. However, following a change in its composition, the Florida Supreme Court swa sponte receded from Walls and decided that Hall announced a new non-watershed rule and was therefore not retroactive. Phillips v. State, 299 So. 3d 1013 (Fla. 2020), cert. denied, 141 S. Ct. 2676 (2021). This case presents the following question: whether Hall’s holding—that the 3pronged test for assessing intellectual disability (not just the first prong of the test) must be informed by prevailing medical practice and standards—announced a new i rule of constitutional law within the meaning of Teague v. Lane, 489 U.S. 288 (1989), as the Florida Supreme Court and the Eleventh Circuit Court of Appeals have held, or was instead simply an application of the rule of Atkins to particular facts, as Petitioner contends and all other courts of appeals’ decisions conclude. ii