Caylor v. State, 78 So. 3d 482

Melinda Hinson, 13, was killed in a Panama City motel; Caylor was the suspect and confessed after Miranda rights were administered.
Caylor was tried on first-degree murder (premeditation and/or felony murder), sexual battery involving great physical force, and aggravated child abuse; DNA and physical evidence linked him to the scene.
Motel room scene showed the body under a bed, with gendered injuries and ligature marks; multiple injuries suggested both manual and ligature strangulation.
Caylor provided inconsistent statements leading to trial, including a theory of consensual sex followed by nonsexual assault; trial evidence included medical examiner testimony and DNA results.
The jury convicted Caylor on all counts; during penalty phase, the court found three aggravators and several mitigators; death sentence imposed after weighing aggravators against mitigators.
On appeal, Caylor challenges acquittals and aggravators, and the constitutionality of Florida’s death penalty under Ring; the State cross-argues sufficiency of evidence for conviction and sentencing

Issue	Plaintiff's Argument	Defendant's Argument	Held
Aggravated child abuse as underlying felony or aggravating factor	Caylor argues Brooks requires merger of aggravated child abuse with homicide	State asserts multiple acts of aggravated battery not subsumed	Aggravated child abuse supported; not error to rely as aggravator
Sexual battery involving great physical force sufficiency	Consent theory plausible; no direct lack of consent evidence	Evidence inconsistent with consent; jury could disbelieve defense	Evidence competent and substantial; jury could find lack of consent; conviction sustained
Felony probation aggravator sufficiency and nexus	Questioning nexus between probation status and murder	statute permits aggravator based on status; no nexus required	Aggravator supported; not preserved challenge but otherwise meritorious
Weight given to dysfunctional family and remorse mitigating factors	Weighing error or misweighting of mitigators	Weight decisions within trial court discretion	Weights supported by record; not error in mitigation analysis
Proportionality and Ring v. Arizona challenge	Death penalty unconstitutional under Ring	Ring does not apply where aggravator found by jury or prior conviction exists	Death sentence proportional; Ring challenge rejected

Brooks v. State, 918 So.2d 181 (Fla.2005) (merger doctrine; aggravated child abuse cannot be separate felony in some contexts)
Mills v. State, 476 So.2d 172 (Fla.1985) (merger of aggravated battery with homicide when only single act caused death)
Hitchcock v. State, 413 So.2d 741 (Fla.1982) (consent considerations in sexual battery involving a minor)
Davis v. State, 698 So.2d 1182 (Fla.1997) (proportionality and mitigation in sex-related murder cases)
Smith v. State, 28 So.3d 838 (Fla.2009) (factors in sexual battery and murder sentencing under Ring framework)
Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (Sixth Amendment requires jury finding of certain aggravators when they function as elements)