Case Explained: LEONARDO FRANQUI v. SECRETARY, FLORIDA DEPARTMENT OF CORRECTIONS

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-10 Docket: 1:11-cv-22858-DLG The eleventh-circuit affirmed the district court’s denial of a federal habeas petition challenging a death sentence on the grounds that the petitioner is intellectually disabled and thus ineligible for execution under the Eighth Amendment. Applying the deferential standard of review prescribed by the Antiterrorism and Effective Death Penalty Act (AEDPA), 28 U.S.C. § 2254(d), the court held that the Florida Supreme Court’s rejection of the petitioner’s claim was not contrary to, or an unreasonable application of, *Atkins v. Virginia*, nor did it rest on an unreasonable determination of facts. The court explained that the state court properly evaluated the three requirements for intellectual disability—significantly subaverage intellectual functioning, concurrent deficits in adaptive behavior, and onset before age eighteen—by considering expert testimony on IQ scores, standard error of measurement, and adaptive functioning across conceptual, social, and practical domains. The appellate court found the state court’s factual determinations were not objectively unreasonable given the record evidence, including testimony regarding potential malingering and the petitioner’s ability to function independently. Consequently, the judgment denying habeas relief remains in effect for the Hialeah case involved in this appeal. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.