Answer Brief of Appellee - Florida State University College of Law

Bob Sarver (Undersheriff) was recalled by the State.
(R1419). None of the clothes line used to bind the victim had
been found anywhere other than the house Hoskins had been
staying in. (R677, 1419, 1421).
Karen Palladino, currently the Director of Administrative
Support Services with Brevard County Schools, formerly worked
with disadvantaged and minority children, as well as special
education children. (R1422-23). Palladino said studies have
reflected racial bias in the language sections of IQ testing
conducted in the 1970’s. “Disadvantaged students may not have
had the experiences that more advantaged students would have had
... may not have had the resources in the home, may not have had
books in the home.” (R1425). In reviewing Hoskins’ school
records, Palladino said, “There’s very little in this record
that indicates he’s (Hoskins) definitely a hyperactive child ...
the behaviors don’t stand out. A lot looks like a student
experiencing academic difficulty from a disadvantaged
environment; not real interested in school, having more problems
with math than other areas, and usually obeyed authorities,
cooperative during the evaluation.” (R1429).
Palladino indicated that a person suffering from frontal
lobe impairment would be “up and down” emotionally, and would
show “anger bursts, not being able to show affection ... zoning
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