On July 24, 2014, a district court in the District of Vermont ordered a new trial for Donald Fell based on juror misconduct uncovered in capital 2255 proceedings in United States v. Fell. The opinion can be read here. This was the first guilt phase reversal in a capital 2255 in many years.
On May 27, 2014, in Hall v. Florida (12-10882), the United States Supreme Court clarified the standards by which courts should consider whether capital defendants are intellectually disabled (mentally retarded) and therefore ineligible for the death penalty. The Court’s holding struck down Florida’s rigid rule declaring that any person with an IQ score above 70 could not be intellectually disabled as being in violation of its 2002 decision in Atkins v. Virginia, 536 U.S. 304 (2002), declaring that the Eighth Amendment prohibits capital punishment for the mentally retarded. The opinion can be read here.
On September 6, 2013, the Eighth Circuit affirmed the denial of § 2255 relief in the case of Wesley Ira Purkey v. United States. The court's opinion can be read here.