A Florida appeals court has affirmed a trial court ruling that Reginald Jackson is intellectually disabled and therefore ineligible for the death penalty, upholding a constitutional bar on capital punishment in such cases.
Jackson was first charged in 2013 with two counts of first-degree murder and other crimes, most notably the killings of Annette Anderson and her grandson, Tyrone Walker. The state sought the death penalty; however, Jackson “moved for an order barring him from eligibility for capital punishment due to intellectual disability,” according to Tracking Florida’s Death Penalty.
An evidentiary hearing on Jackson’s claim was conducted in 2019. According to Tracking Florida’s Death Penalty, the hearing found that, “After hearing testimony and reviewing hundreds of pages of school, jail, and juvenile detention records, and other documents, as well as detailed post-hearing memoranda the parties submitted, the trial court rendered a fifteen-page written order finding Jackson intellectually disabled.”
The state appealed the decision to the Third District Court of Appeal, arguing “that the trial court misconstrued the record, which lacks clear and convincing evidence to support its order, and considered factors other than those required to prove intellectual disability.” The state also challenged the evidence of deficits in Jackson’s current level of adaptive behavior or functioning, contending that the trial court focused primarily on evidence from his childhood, according to Tracking Florida’s Death Penalty.
Jackson countered that the ruling was supported by substantial evidence, a position with which the Third District Court of Appeal agreed. The court ultimately affirmed the finding that Jackson was and is intellectually disabled and therefore ineligible for the death penalty, according to Tracking Florida’s Death Penalty.
The court noted that Jackson “had two full-scale IQ scores . . . that were low enough to require further adaptive functioning analysis.” The court also found that Jackson was born while his mother was actively abusing drugs and that his father “beat his mother, both during and after pregnancy.” Further, “[e]ven the state’s expert . . . acknowledged that Jackson suffered neurological problems and difficulties due to his mother’s drug and alcohol use during her pregnancy.” Jackson also suffered several head injuries during his developmental period.
Records showed that Jackson “[n]ever surpassed the academic level of a sixth grader.” Multiple witnesses testified that Jackson often had difficulty performing simple tasks.
His grandmother stated that he did not know how to tell time at age seven, struggled to count money and could not write his name at age five. She also testified that he could not complete tasks and had difficulty controlling his emotions.
The court further found that Jackson was “significantly deficient” in the practical domain. His sister reported that he had to be reminded to bathe and would wear the same clothes for days at a time.
His grandmother testified that he did not know how to prepare simple meals and that his primary chore growing up was taking out the trash, which he often had to be reminded to do.
Although the state may seek review from the Florida Supreme Court, the court’s jurisdiction is limited, making reversal unlikely. The trial court’s findings were supported by a substantial evidentiary record, and the Third District Court of Appeal affirmed that the legal standards for determining intellectual disability were properly applied.
As a result, Jackson remains ineligible for the death penalty under Florida law, reinforcing the constitutional prohibition against executing individuals with intellectual disabilities.
Follow the Vanguard on Social Media – X, Instagram and Facebook. Subscribe the Vanguard News letters. To make a tax-deductible donation, please visit davisvanguard.org/donate or give directly through ActBlue. Your support will ensure that the vital work of the Vanguard continues.
