Chandler v. State
75 So. 3d 267
Fla.2011Background
- Chandler, a prisoner with three death sentences under active death warrant, seeks postconviction relief in Florida courts.
- He filed a successive motion under Florida Rule of Criminal Procedure 3.851 alleging Ring-based invalidity of the penalty phase.
- The circuit court denied the motion and a stay; appellate counsel was appointed and this Court reviewed the denial.
- Chandler’s convictions and death sentences were previously affirmed on direct review; Ring challenges are not retroactive per controlling authorities.
- The circuit court held Ring not retroactive and also inapplicable due to prior violent felonies and contemporaneous murders, and ruled the motion procedurally barred.
- This Court affirmed, rejecting the Ring-based relief and denying a stay of execution.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ring retroactivity to final convictions | Chandler argues Ring is retroactive. | State contends Ring is not retroactive. | Ring not retroactive. |
| Ring applicability with prior violent felonies | Ring should apply despite prior aggravators. | Ring exceptions cover prior felonies. | Ring does not apply due to prior violent felony aggravators. |
| Ring and contemporaneous multiple murders | Ring should invalidate death for contemporaneous murders. | Frances and related doctrine keep Ring out. | Ring not applicable where contemporaneous murders supported by same jury verdict. |
| Procedural bar under 3.851(d)(2) | Motion should not be procedurally barred. | Bar applies because no newly discovered evidence or retroactive right shown. | Procedural bar applies. |
| Overall viability of Ring-based relief | Chandler merits a new penalty phase. | Relief not warranted under governing authorities. | Relief denied; no stay issued. |
Key Cases Cited
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (requires jury finding of facts increasing max sentence)
- Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (broad principle for sentencing enhancements)
- Schriro v. Summerlin, 542 U.S. 348 (U.S. 2004) (Ring not retroactive to final convictions)
- Johnson v. State, 904 So.2d 400 (Fla. 2005) (Ring not retroactive in Florida context)
- Chandler v. State, 702 So.2d 186 (Fla. 1997) (direct-review affirmation of convictions and deaths)
- Chandler v. Crosby, 454 F.Supp.2d 1137 (M.D. Fla. 2006) (federal postconviction proceedings)