Hamm v. Smith · ¶159
Start with Hall. To be sure, the defendant in that case had taken multiple IQ tests. 572 U. S., at 707. But neither the Florida courts nor this Court considered the cumulative significance of his scores. See Hall v. State, 109 So. 3d 704, 707–711 (Fla. 2012) (per curiam); Hall, 572 U. S., at 724. Under then-controlling Florida case law, state courts considered each score individually. See Cherry v. State, 959 So. 2d 702, 712–714 (Fla. 2007). Unless a defendant provided at least one score of 70 or below, Florida courts would deny relief. Although Hall rejected this approach, the decision did not explain how courts should consider the cumulative significance of multiple scores. To the extent that Hall addressed multiple-score analysis at all, it held only that courts must “take into account” potential measurement error. 572 U. S., at 724. Hall did not, however, explain how to account for…Read in context ›
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