Sonny Boy Oats, Jr. v. Julie L. Jones, etc.

Summary

The Florida Supreme Court denied Sonny Boy Oats, Jr.'s petition for a writ of habeas corpus. The court held that Hurst relief did not apply retroactively to Oats's 1985-final death sentence and that Florida law permits the trial judge, rather than a jury, to determine intellectual disability in an Atkins-related proceeding. Justice Pariente and Justice Lawson filed concurring opinions.

Holdings

1. Hurst v. State does not apply retroactively to Oats's death sentence because the sentence became final in 1985.
2. Florida law permits the trial judge, rather than a jury, to determine whether a capital defendant is intellectually disabled and therefore ineligible for execution.
3. Oats failed to demonstrate that Florida's procedure under section 921.137 and Florida Rule of Criminal Procedure 3.203, assigning intellectual-disability determinations to the trial judge, is unconstitutional.

Questions Presented

1. Whether Hurst v. State applied retroactively to Oats's death sentence, which became final in 1985.
2. Whether Hurst v. Florida, Hurst v. State, Ring v. Arizona, Atkins v. Virginia, or Hall v. Florida required a jury, rather than the trial judge, to determine whether Oats was intellectually disabled and therefore ineligible for execution.
3. Whether Florida's statutory and procedural scheme assigning intellectual-disability determinations to the trial judge was unconstitutional.

Disposition

writ_denied