Whether the Eighth Amendment prohibits the execution of an intellectually disabled defendant when state courts have arbitrarily applied time bars that prevent a full and meaningful opportunity to prove intellectual disability

by Pittman’s case require a full appellate review that is not truncated by his imminent execution. For the foregoing reasons, Pittman respectfully requests that this Court grant his application for a stay of Pittman’s execution scheduled for September 17, 2025, to address the compelling constitutional questions in his case on the merits. Respectfully submitted, /s/ Julissa R. Fontan Julissa R. Fontan Florida Bar #0032744 Assistant Capital Collateral Counsel Law Office of the Capital Collateral Regional Counsel — Middle Region 12973 N. Telecom Parkway Temple Terrace, FL 33637 (813)558-1600 Counsel of Record /s/ Megan M. Montagno Megan M. Montagno Florida Bar #118819 Assistant Capital Collateral Counsel Law Office of the Capital Collateral Regional Counsel — Middle Region 12973 N. Telecom Parkway Temple Terrace, FL 33637 (813)558-1600 IN THE SUPREME COURT OF THE UNITED STATES DAVID JOSEPH PITTMAN, Petitioner, vs. STATE OF FLORIDA, Respondent. PROOF OF SERVICE DEATH WARRANT SIGNED Execution Scheduled: Sept