Askari Abdullah Muhammad f/k/a Thomas Knight v. State of Florida
132 So. 3d 176
| Fla. | 2014Background
- Muhammad is a death-sentenced inmate challenging a successive postconviction motion under Fla. R. Crim. P. 3.851 filed after a death warrant was signed in 2013.
- He was convicted for the October 12, 1980 murder of correctional officer James Burke while on death row for prior killings.
- Prior appellate and postconviction proceedings included competence findings, self-representation, and Brady-related claims; a pretrial and trial history culminated in a death sentence upheld on direct appeal.
- In 2005 he pursued habeas relief in federal court, which denied relief and a COA was denied by the Eleventh Circuit; in 2008 he filed a successive 3.851 claim addressing lethal injection procedures.
- The 2013 proceeding sought relief on multiple grounds: lethal injection methods, public records requests, discovery, and related due process concerns; the majority held midazolam hydrochloride may warrant an evidentiary hearing while affirming most postconviction denials.
- The court ultimately affirmed most claims, but reversed on the public records portion to require production of Muhammad’s inmate and medical records to his counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of midazolam-first three-drug protocol | Muhammad argues midazolam first drug risks pain and violates Eighth Amendment and Florida Constitution. | State argues protocol, properly administered with consciousness checks, does not present an impermissible risk of pain. | Protocol not unconstitutional; evidence shows proper administration yields unconsciousness and no pain. |
| Evidentiary hearing rulings and witness subpoenas | Muhammad contends circuit court abused its discretion by excluding witnesses and quashing journalist subpoenas. | State contends rulings were within discretion given narrow issue and relevance limits. | No abuse of discretion; rulings upheld. |
| Public records access under 3.852 | Muhammad sought updated inmate/medical records and broader materials to support colorable claims. | DOC and agencies argued overbreadth; records beyond colorable claims should be denied. | DOC records must be produced; other requests denied as overbroad or noncolorable. |
| Clemency process due process | Clemency process was manipulated; denial of equitable clemency review denied Muhammad due process. | Clemency is executive prerogative with no mandated procedures; due process not violated. | Clemency claims rejected; process remains executive prerogative. |
| Timely Justice Act of 2013 constitutionality | Amendments undermine court authority and defendants’ rights; warrant/ execution timing pressured by Act. | Act not challenged on merits here; Governor’s signing deemed unrelated to case-specific reasons. | Constitutionality not reached; affirm denial of postconviction relief on this point. |
Key Cases Cited
- Lightbourne v. McCollum, 969 So.2d 326 (Fla. 2007) (Florida lethal injection protocol approved after evidentiary hearing)
- Valle v. State, 70 So.3d 530 (Fla. 2011) (Eighth Amendment challenges to changes in protocol require substantial risk of harm)
- Pardo v. State, 108 So.3d 558 (Fla. 2012) (One-drug protocol not mandated by evolving standards of decency)
- Marek v. State, 14 So.3d 985 (Fla. 2009) (Clemency claims and executive prerogative considerations)
- Baze v. Rees, 553 U.S. 35 (U.S. 2008) (Constitutional standard for risk of pain in lethal injection protocols)
- Johnston v. State, 27 So.3d 11 (Fla. 2010) (Clemency-related due process considerations and governance)
- Carroll v. State, 114 So.3d 883 (Fla. 2013) (Clemency process and executive discretion regarding clemency)
- Simmons v. State, 105 So.3d 475 (Fla. 2012) (Mental illness and death penalty-related arguments rejected)