History of the Case

It is reported that the defendant was convicted of first-degree felony murder, aggravated child abuse, and sexual battery stemming from the 1992 death of a two-year-old child. The prosecution’s evidence showed that the child suffered severe blunt force injuries while in the defendant’s care, and the medical examiner concluded that the cause of death was a cerebral hemorrhage resulting from four separate blows to the head. The defendant, however, testified that the child experienced a medical emergency while another person was present in the apartment and that he accidentally dropped her in the shower while attempting to revive her. The jury rejected this account and recommended a death sentence, which the trial court imposed.

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Background of the Case

It is reported that the defendant was convicted of first-degree murder and kidnapping and sentenced to 100 years in prison and death. He filed a postconviction motion, resulting in the vacation of his death sentence and the ordering of a new penalty phase. The defendant then filed a second motion, claiming newly discovered evidence based on an alleged jailhouse confession. An evidentiary hearing was conducted, during which the defendant presented testimony from witnesses, including the individual to whom the alleged confession was made.

Allegedly, the court denied the defendant’s motion for relief, concluding that the evidence presented was insufficient to support the claim of a jailhouse confession and would likely be inadmissible under the Florida Rules of Evidence. Consequently, the defendant appealed the court’s decision. 

Setting Aside a Conviction Due to Newly Discovered Evidence 

On appeal, the court affirmed the trial court ruling. In its opinion, it explained that to set aside a conviction based on newly discovered evidence, two requirements must be met: (1) the evidence must not have been known at the time of trial and could not have been discovered with due diligence, and (2) the newly discovered evidence must be of such nature that it would probably result in an acquittal on retrial by weakening the case against the defendant to raise a reasonable doubt about their guilt.

In the subject case, the court found that the defendant satisfied the first requirement, as the evidence in question was not known at the time of trial. Since the court ultimately determined that the alleged confession did not occur, however, it held that the defendant failed to meet the second requirement. Thus, the court upheld the trial court ruling.

Talk to a Dedicated Florida Criminal Defense Attorney

Murder and other violent offenses carry substantial punishments, including, in some cases, the death penalty. If you are charged with murder or another violent crime, it is critical to talk to an attorney about what strategies you can employ to protect your interests. The dedicated St. Petersburg criminal defense lawyers of Hanlon Law are well-equipped to help people charged with violent crimes seek favorable outcomes, and if you hire us, we will advocate zealously on your behalf. You can reach us to set up a meeting by calling us at 727-897-5413 or using our online form.

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Factual and Procedural History

It is reported that the defendant, who was incarcerated, was suspected of attacking another inmate. The victim, who died from his injuries, was briefly interviewed prior to his death and named the defendant as the person who both bound his hands and feet and stabbed him. The defendant was interviewed as well, admitting to tying the victim up but stated he blacked out after that due to anger, and could not recall what happened. The defendant was charged with first-degree murder, to which he pleaded guilty.

Allegedly, the prosecution and defense counsel both then agreed to enter the defendant’s competency evaluation reports into evidence. The defendant was ultimately sentenced to death. Following his sentencing, he appealed, arguing in part that the court violated his right to due process by failing to conduct a competency hearing.

The Right to a Competency Hearing

Under Florida law, when a court is tasked with determining whether a defendant is competent to proceed to trial, it must assess whether the defendant has a current and sufficient ability to confer with his or her attorney with a reasonable degree of understanding and whether the defendant has a logical and factual understanding of the proceedings against him or her. The court noted that while under Florida law, it is an error to refuse to provide a competency hearing when there are reasonable grounds to suspect that a defendant is mentally insane and defense counsel requests a competency hearing, those facts were not present in this case.

Specifically, the two experts that evaluated the defendant prior to the trial found him to be competent, the prosecution, defense counsel, and the trial judge agreed that the defendant was competent, and defense counsel did not object to the introduction of the expert reports or request to introduce any additional evidence on the issue. As such, the appellate court found that there was no abuse of discretion and affirmed the trial court ruling.

Meet with a Capable St. Petersburg Attorney

If you live in St. Petersburg and are charged with murder or any other serious crime, it is essential to retain an attorney who will fight to protect your interests. William Hanlon of Hanlon Law is a capable St. Petersburg violent crime defense attorney with the knowledge and experience needed to help you seek a favorable outcome, and he will work tirelessly on your behalf. You can reach Mr. Hanlon through the form online or at 727-897-5413 to set up a meeting.

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The Defendant’s Conviction and Appeal

It is alleged that the defendant was charged with and convicted of first-degree murder of his ex-girlfriend, attempted first-degree murder with a firearm, and burglary. He was sentenced to death for the first-degree murder conviction, and the sentence eventually became final. The defendant then filed a post-conviction motion asking the court for relief on several grounds. The court denied the defendant’s motion and affirmed his sentence. The defendant then appealed.

Post-Conviction Defenses

First, the defendant argued on appeal that he was entitled to relief under Atkins v. Virginia, a United States Supreme Court case and cases that were subsequently decided in the Florida courts, on the grounds that he suffered from an intellectual disability. The court rejected this assertion, stating that the law was clear that relief for an intellectual disability could not be granted retroactively. Thus, the court affirmed the lower court ruling dismissing the petition for relief due to intellectual disability as time-barred.

Further, the defendant sought relief under a second United States Supreme Court case, Hurst v. State, which ruled that pursuant to the Sixth Amendment of the United States Constitution, a court could not impose a death-penalty sentence unless the jury ruling on the defendant’s guilt found aggravating factors. Although the defendant was sentenced prior to the Hurst ruling, he was convicted of attempted first-degree murder with a firearm and burglary, which under Florida law is sufficient to satisfy the requirement that the jury finds an aggravating circumstance unanimously and beyond a reasonable doubt. The court further rejected that it did not violate the defendant’s rights under Florida law to refer to a jury’s role in any decisions rendered prior to Hurst as advisory, noting that a defendant could not use current case law to attempt to retroactively argue that jury instructions that were proper at the time they were issued are now improper under Florida law. As such, the court affirmed the lower court ruling denying the defendant’s petition to vacate his sentence pursuant to Hurst.

Speak to a Proficient Criminal Defense Attorney

If you are a resident of  St. Petersburg that was recently charged with a violent crime, it is prudent to speak to an attorney regarding what defense you may be able to set forth to avoid a conviction or a lengthy sentence. William Hanlon of Hanlon Law is a dedicated St. Petersburg violent crime defense attorney who fights to help criminal defendants seek the best outcome available under the circumstances. Mr. Hanlon can be contacted through the online form or at 727-897-5413 to schedule a conference.

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