State of Florida v. Reginald Jackson

Summary

The Third District Court of Appeal of Florida affirmed a non-final order finding Reginald Jackson intellectually disabled under section 921.137(1), Florida Statutes, and Florida Rule of Criminal Procedure 3.203. The court held that competent, substantial evidence supported the trial court’s findings regarding significantly subaverage intellectual functioning, manifestation before age eighteen, and adaptive-functioning deficits. The determination barred the potential imposition of the death penalty.

Holdings

1. The trial court's finding that Jackson had significantly subaverage general intellectual functioning was supported by competent, substantial evidence, including multiple low IQ scores, consideration of the standard error of measurement, and academic records showing significant deficits.
2. The trial court's finding that Jackson's intellectual disability manifested during the developmental period was supported by competent, substantial evidence; Florida law requires manifestation before age eighteen, not a formal childhood diagnosis.
3. The trial court properly found that Jackson had adaptive-functioning deficits sufficient to satisfy the second prong of the intellectual-disability standard because the evidence showed substantial deficiencies in the conceptual and practical domains and supported an ongoing impairment.
4. The trial court's finding, by clear and convincing evidence, that Jackson was intellectually disabled was supported by competent, substantial evidence, and the appellate court would not reweigh the evidence or second-guess the trial court's factual findings.

Questions Presented

1. Whether the trial court's finding that Jackson had significantly subaverage general intellectual functioning was supported by competent, substantial evidence.
2. Whether the trial court's finding that Jackson's intellectual disability manifested before age eighteen was supported by competent, substantial evidence.
3. Whether the trial court properly found concurrent and current deficits in adaptive behavior sufficient to satisfy the second prong of Florida's intellectual-disability standard.
4. Whether the trial court properly applied the clear-and-convincing-evidence standard and considered both evidence of adaptive limitations and evidence offered to rebut those limitations.

Disposition

affirmed