Carroll v. State
114 So. 3d 883
| Fla. | 2013Background
- Carroll is a death-sentenced prisoner with a current death warrant; direct and postconviction history precedes this appeal.
- He was convicted of 1990 first-degree murder and sexual battery of a 10-year-old; jury recommended death; trial court found three aggravators.
- Direct appellate review affirmed the death sentence; multiple postconviction motions and federal petitions followed over the years.
- In 2013, Governor Scott signed a death warrant; Carroll filed a successive postconviction motion raising four claims; a Huff hearing occurred.
- Circuit court summarily denied relief on all claims, ruling some as procedurally barred and others meritless.
- Proceedings on review focus on whether Carroll’s claims warrant relief under Florida Rule of Criminal Procedure 3.851.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Mental illness claim untimely and barred | Carroll argues Atkins/Roper should apply to mentally ill defendants to bar execution. | State contends the claim is not a newly recognized retroactive right and is procedurally barred; merits lack. | Claim procedurally barred and merits rejected |
| Governor's unfettered discretion to sign death warrants unconstitutional | Carroll asserts arbitrary, standards-less gubernatorial execution power violates rights. | State relies on established precedent upholding Governor's discretion. | Claim without merit; precedent maintained |
| Clemency process arbitrary and capricious | Carroll argues clemency process failed Harbison fail-safe and due process protections. | State notes clemency hearing occurred and Florida executive clemency prerogative is exclusive. | Claim without merit; no constitutional violation |
| Prolonged time on death row constitutes cruel and unusual punishment | Carroll contends long wait, combined with execution, violates Eighth Amendment and international norms. | State cites extensive state precedent rejecting such claims; delay largely due to petitioning conduct. | Claim rejected; no cruel/unusual punishment |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (death penalty barred for under-18 defendants)
- Atkins v. Virginia, 536 U.S. 304 (U.S. 2002) (death penalty barred for mental retardation)
- Harbison v. Bell, 556 U.S. 180 (U.S. 2009) (clemency as a fail-safe in capital cases)
- Marek v. State, 14 So.3d 985 (Fla. 2009) (rejecting clemency process challenges; limits on judicial review)
- Johnston v. State, 27 So.3d 11 (Fla. 2010) (no merit in mental illness extension to Atkins/Roper claims)
- Valle v. State, 70 So.3d 530 (Fla. 2013) (delay on death row not new constitutional violation)
- Pardo v. State, 108 So.3d 558 (Fla. 2012) (clemency and due process considerations in Florida)
- Gore v. State, 91 So.3d 769 (Fla. 2013) (death sentence delay; no international-law violation)
- Ferguson v. State, 101 So.3d 362 (Fla. 2012) (upholding Governor's discretion and related procedures)