Whether the Eighth Amendment prohibits the execution of an intellectually disabled defendant when state courts have arbitrarily interpreted federal law to bar substantive intellectual disability claims

by Walls’ case require a full appellate review that is not truncated by his imminent execution. For the foregoing reasons, Walls respectfully requests that this Court grant his application for a stay of Walls’ execution scheduled for December 18, 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 No. 118819 Assistant CCRCMiddle Region Law Office of the Capital Collateral Regional Counsel — Middle Region 12973 N. Telecom Parkway Temple Terrace, FL 33637 Counsel for Petitioner Dated: December 15, 2025