Oats v. Jones

Petitioner was convicted for the robbery of a convenience store and first-degree murder of the store clerk. Petitioner was sentenced to death for the murder. In 2015, the Supreme Court remanded Petitioner’s case because to the circuit court for a new intellectual disability hearing. Following the Supreme Court’s opinion in Hurst v. State, 202 So. 3d 40, Petitioner filed a postconviction motion seeking relief under Hurst. Petitioner then filed this petition for a writ of habeas corpus, arguing that he was entitled to have his death sentence vacated pursuant to Hurst and that the determination of whether a defendant is intellectually disabled is a fact that must be found by the jury. The Supreme Court denied Petitioner’s petition, holding (1) Petitioner was not entitled to Hurst relief because Hurst does not apply retroactively to Petitioner's sentence, which became final in 1985; and (2) the United States Supreme Court’s decision in Hurst v. Florida, 136 S. Ct. 616 (2016), and this court’s decision in Hurst does not require that the jury, rather than the trial judge, determine intellectual disability. Further, Petitioner failed to demonstrate that Florida’s implementation of Atkins v. Virginia, 536 U.S. 304 (2002), as set forth in Fla. Stat. 921.137, is unconstitutional. View "Oats v. Jones" on Justia Law