After Atkins v. Virginia held that the Eighth Amendment bars execution of persons with intellectual disability, Freddie Lee Hall challenged Florida’s method for determining intellectual disability. Hall’s IQ scores included a score of 71, but Florida treated an IQ above 70 as conclusive and would not permit him to present additional evidence of adaptive deficits. The Supreme Court held that rule unconstitutional. The Court reasoned that IQ tests are inherently imprecise and produce a range rather than a fixed number, reflected by the standard error of measurement. Florida’s rigid cutoff therefore disregarded established medical practice and prevented courts from considering relevant evidence about adaptive functioning, including a defendant’s past performance, environment, and upbringing. The Court also relied on the post-Atkins direction of state legislation and its own independent judgment that the rule created an unacceptable risk of executing a person with intellectual disability. Hall may or may not ultimately qualify, but he had to receive a fair opportunity to present the additional evidence. The Court reversed the Florida Supreme Court and remanded. Justice Alito, joined by the Chief Justice and Justices Scalia and Thomas, dissented, finding no sufficient national consensus against Florida’s method.