Bright v. State
90 So. 3d 249
| Fla. | 2012Background
- Bright murdered Derrick King and Randall Brown with a hammer in his Jacksonville home; evidence included a hammer with victim blood, cast-off blood on ceiling, and multiple defensive wounds.
- A contemporaneous premeditated murder conviction supported by autopsy findings and scene evidence; two deaths resulted in separate death sentences.
- Bright made statements to others describing a self-defense narrative; prosecutors argued these accounts contradicted physical evidence.
- During penalty phase, Bright’s prior violent felony conviction (1990 robbery) and HAC were found as aggravators with extensive nonstatutory mitigation.
- The court sentenced Bright to death after weighing aggravators against mitigating evidence, including Bright’s Marine Corps service and family-oriented background.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the evidence supports first-degree premeditated murder | Bright admits killing but asserts self-defense | State argues overwhelming evidence shows premeditation | Sufficient evidence supports conviction |
| Whether closing–argument comments preserved, and prejudiced Bright | Prosecutor commented on Bright’s silence; preserved by objection | No contemporaneous objection; not preserved | Not preserved; if preserved, no reversible error under abuse of discretion |
| Whether trial court improperly doubled the prior-violent-felony aggravator | Two separate findings for same factor | Single aggravator; weight could be greater for multiple felonies | Harmless error; HAC and prior-violent-felony still supported death sentence |
| Whether HAC weighting and mitigation were proper | HAC weights excessive given mitigation | HAC appropriately weighed; substantial brutal attacks justify weight | No abuse of discretion; proportionality maintained |
| Whether overall mitigation outweighed aggravation | Mitigating evidence insufficient to offset two HAC and prior felon | Mitigating factors substantial; death warranted | Death sentence upheld as proportionate in light of aggravation |
Key Cases Cited
- Blake v. State, 972 So.2d 889 (Fla. 2007) (independent review of death-sentence sufficiency)
- Nixon v. State, 572 So.2d 1336 (Fla. 1990) (contemporaneous objection requirement for closing-argument review)
- State v. Jones, 867 So.2d 398 (Fla. 2004) (contextual test for prosecutorial comments on silence)
- Dessaure v. State, 891 So.2d 455 (Fla. 2004) (abuse-of-discretion standard for mistrial/closing remarks)
- Tanzi v. State, 964 So.2d 106 (Fla. 2007) (double-counting aggravators; single aggravator with greater weight permissible)
- DiGuilio v. State, 491 So.2d 1129 (Fla. 1986) (harmless vs. reversible error standard for improper aggravation)