Alan Lyndell Wade v. State of Florida, 156 So. 3d 1004

Wade was convicted of two counts of first-degree murder, kidnapping, and robbery in the July 2005 Sumners murders and received two death sentences.
Wade’s codefendants were Michael Jackson and Tiffany Cole; Nixon pleaded guilty to two counts of second-degree murder with concurrent sentences.
The direct appeal upheld the convictions and death sentences as proportional and supported by the evidence.
In 2011 Wade filed a postconviction motion under Florida Rule 3.851 raising numerous claims of ineffective assistance and other errors.
The postconviction court held hearings and denied relief; Wade appeals challenging guilt-phase and penalty-phase representation and voir dire.
The Florida Supreme Court affirms, upholding the denial of postconviction relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Guilt-phase IAC—suppression and evidentiary objections	Wade asserts trial counsel failed to suppress or object to tainted evidence.	Wade contends counsel should have challenged the hotel-room search and items seized.	No deficient performance; evidence supported result.
Guilt-phase IAC—tape recording and room 302 evidence	Recording of Jackson and Cole misused; violates hearsay rules.	Recording admissible; strategic choice not to object.	Recording admissible; no prejudice shown.
Evidence from room 312 and related exhibits	Bank records and check from room 312 unfairly prejudicial to Wade.	Evidence relevant to co-perpetrators and money transfer; no undue prejudice.	Not unduly prejudicial; within strategic defense theory.
Penalty-phase mitigation—mental health and brain-damage evidence	Failure to obtain mental health evaluation and present brain-damage mitigation.	Wade refused cooperation; trial strategy reasonably chose not to pursue.	No ineffective assistance; no proven prejudice.
Voir dire and jury-wile issues	Counsel misstates weighing law and inadequately challenges biased jurors.	Any misstatements did not prejudice given proper jury instructions.	No reversible error; no Strickland prejudice shown.

Strickland v. Washington, 466 U.S. 668 (1984) (establishes deficient performance and prejudice standard)
Franks v. Delaware, 438 U.S. 154 (1978) (omitted material from affidavits can render warrants defective)
Atwater v. State, 788 So.2d 223 (Fla. 2001) (strategic concessions may be reasonable defense strategy)
Dennis v. State, 817 So.2d 741 (Fla. 2002) (Morton rationale on impeachment and witness testing applicability)
Diaz v. State, 860 So.2d 960 (Fla. 2003) (HAC/mitigation context for appellate review)