Baker v. State, 71 So. 3d 802

Baker and Roosa planned to rob a Daytona Beach house to obtain funds for moving to New York, using a stolen pistol.
They selected Elizabeth Uptagrafft’s home; Baker attacked Elizabeth with a gun and Burns, affording during a multi-hour home invasion and kidnapping.
Stolen jewelry and Elizabeth’s ATM card were taken; Elizabeth was coerced to accompany them, and her PIN was divulged.
A statewide BOLO was issued; police stopped a vehicle matching the description; a high-speed chase ensued and Baker was captured, with Roosa detained.
Baker confessed during interrogation after being read Miranda rights; Elizabeth’s body was later found in a Mondex location.
Trial resulted in convictions for first-degree murder, home invasion robbery, kidnapping, and aggravated fleeing and eluding; the jury recommended death.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of post-arrest confession	Baker contends confession was involuntary due to coercive promises.	State argues statements were voluntary given totality of circumstances and Miranda warnings.	Confession admitted; no coercive conduct established; voluntary under totality of circumstances.
Failure to read/readings of an apology letter in penalty phase	Baker seeks to read apology; trial court precluded or declined ruling on contents.	State argues issue not preserved due to lack of proffer.	Issue unpreserved; no relief.
Admission of victim impact statements in penalty phase	Victim impact statements are improper or exceed statutory limits.	Statements fall within 921.141(7) and Florida Constitution rights of victims' family to be heard.	Admissible; within statutory and constitutional scope.
Sufficiency of evidence for CCP and HAC and proportionality	Trial court properly found CCP and HAC; death penalty proportionate given circumstances.	CCP and HAC not supported; death penalty not proportionate in light of mitigating factors.	CCP and HAC supported; death sentence proportionate under the record.
Ring v. Arizona challenge to Florida's scheme	Ring requires jury finding of aggravators equivalent to elements.	Flatly rejects Ring challenges; longstanding Florida approach applies when felony-murder theory is applicable.	Ring not implicated; no relief.

Blake v. State, 972 So.2d 839 (Fla.2007) (confession not involuntary absent coercive promises in totality of circumstances)
Owen v. State, 862 So.2d 687 (Fla.2003) (defendant’s own offer of a deal relevant to voluntariness; no coercion if fully aware of rights)
Maqueira v. State, 588 So.2d 221 (Fla.1991) (cooperation promises to prosecutors not per se rendering confession involuntary)
Bush v. State, 461 So.2d 936 (Fla.1984) (confession not involuntary merely because police say cooperation helps)
Franklin v. State, 965 So.2d 79 (Fla.2007) (mitigation vs aggravation in proportionality assessment)
Lynch v. State, 841 So.2d 362 (Fla.2003) (four-part CCP test for cold, calculated, premeditated killing without justification)
Routly v. State, 440 So.2d 1257 (Fla.1983) (HAC evidence often arises from victim’s agony before death)
Dixon v. State, 283 So.2d 1 (Fla.1973) (HAC standard: conscienceless, pitiless, unnecessarily torturous)
Francis v. State, 808 So.2d 110 (Fla.2001) (merging of pecuniary-gain with murder in course of robbery guidance)
Ring v. Arizona, 536 U.S. 584 (U.S.2002) (jury findings required for aggravating circumstances when they function as elements)