Williams v. State

The Supreme Court affirmed the postconviction court’s order denying Appellant’s claims raised in his motion to vacate his conviction of first-degree murder and sentence of death, with the exception of Appellant’s ineffective assistance of penalty phase counsel claim, which the court did not address because Appellant was entitled to a new penalty phase in light of Hurst v. State, 202 So. 3d 40 (Fla. 2016). The court vacated Appellant’s sentence of death and remanded for a new penalty phase, holding (1) regarding the non-unanimous jury recommendation to impose a sentence of death in this case, it cannot be said that the failure to require a unanimous verdict was harmless; (2) Appellant did not qualify as intellectually disabled under Florida law, and therefore, the postconviction court did not err when it denied Appellant’s claim that he was intellectually disabled; and (3) Appellant failed to establish that Fla. Stat. 27.7081 and Fla. R. Crim. P. 3.851 are unconstitutional either facially or as applied. View "Williams v. State" on Justia Law