Antonio Lebaron Melton v. State of Florida
193 So. 3d 881
Fla.2016Background
- Antonio Lebaron Melton was convicted in 1992 of felony murder and armed robbery; sentenced to death; convictions affirmed on direct appeal and in prior postconviction proceedings.
- Melton filed a successive postconviction motion asserting newly discovered evidence and Brady/Giglio claims based on statements by codefendant Bendleon Lewis.
- In 2013 defense investigators reported Lewis told them there had been a struggle over the gun before the fatal shot and that Lewis had a plea agreement before testifying at Melton’s 1992 trial.
- At the 2014 evidentiary hearing Lewis denied the investigators’ account and testified consistently with his trial testimony that no promise had been made though he hoped for leniency; the trial court found Lewis credible.
- The circuit court denied relief, concluding the alleged new evidence would not likely produce acquittal or a lesser sentence and that Melton failed to prove Brady/Giglio violations. The Supreme Court of Florida affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Newly discovered evidence (recantation/struggle) | Lewis’s alleged 2013 statements to investigators that there was a pre‑shot struggle and a preexisting plea deal are new and would create reasonable doubt and affect sentencing | Jury already knew of Lewis’s motives/immunity; trial evidence (possession of gun, victim’s blood on Melton) strongly supports conviction and aggravators remain | Denied — court accepted Lewis’s hearing testimony; new evidence would not likely produce acquittal or lesser sentence |
| Brady claim (suppression of plea agreement) | State withheld evidence that it had negotiated/finalized a plea agreement with Lewis before his trial testimony | No competent, substantial evidence that a formal agreement existed pretrial; jury was aware of Lewis’s incentives; no suppression shown | Denied — Melton failed to prove the State possessed or suppressed a plea agreement or that outcome would differ |
| Giglio claim (knowing use of false testimony) | Lewis testified falsely at trial about promises; prosecutor knew and failed to correct it | Lewis’s trial and hearing testimony were consistent; no proof testimony was false or that prosecutor knew falsity | Denied — no competent proof of false testimony or prosecutor knowledge; no Giglio violation |
| Cumulative effect on penalty phase | Discounting Lewis’s testimony would eliminate basis for death and yield life sentence | Strong prior‑violent‑felony aggravator and pecuniary‑gain aggravator would still permit death; removal of Lewis’s testimony unlikely to change sentence | Denied — even cumulatively, new evidence unlikely to produce lesser sentence |
Key Cases Cited
- Jones v. State, 709 So. 2d 512 (Fla. 1998) (two‑part newly discovered evidence test)
- Jones v. State, 591 So. 2d 911 (Fla. 1991) (new evidence standard as applied to sentencing)
- Lightbourne v. State, 742 So. 2d 238 (Fla. 1999) (cumulative analysis of postconviction evidence)
- Hildwin v. State, 141 So. 3d 1178 (Fla. 2014) (consideration of all admissible newly discovered evidence)
- Brady v. Maryland, 373 U.S. 83 (1963) (government duty to disclose favorable evidence)
- Giglio v. United States, 405 U.S. 150 (1972) (prosecutor must correct known false testimony)
- Kyles v. Whitley, 514 U.S. 419 (1995) (materiality standard for suppressed evidence)