Charles C. Peterson v. State of Florida, 154 So. 3d 275

Peterson was convicted of first-degree murder (Big Lots robbery) and sentenced to death after a jury recommendation (8–4); conviction affirmed on direct appeal.
At trial three Big Lots employees identified Peterson as the robber; the State introduced three collateral "Williams rule" robbery cases linking Peterson to similar crimes.
Postconviction (Rule 3.851) Peterson argued ineffective assistance of trial counsel across multiple categories (juror selection, failure to suppress/attack identifications, failure to present mitigation, and cumulative error); an evidentiary hearing was held and relief was denied.
Peterson also filed a habeas petition claiming appellate counsel was ineffective for misstating that Peterson had been convicted in all three collateral robberies when record showed conviction only in one.
The Florida Supreme Court reviewed the Strickland standard, rejected Peterson’s remaining claims (juror bias/peremptories; failure to use an eyewitness-identification expert or to move to suppress identifications; mitigation and cumulative-error claims), found appellate counsel made a factual error but held Peterson failed to show prejudice, and denied habeas relief.

Issue	Peterson's Argument	State's Argument	Held
Juror bias — failure to challenge for cause	Trial counsel should have struck five jurors for cause due to alleged bias	Record shows no actual bias; counsel’s voir dire strategy reasonable	Denied — no showing of actual bias; claim fails Strickland prejudice prong
Juror selection — improper use of peremptories	Counsel should have used peremptories differently to seat a more favorable jury	Counsel strategically balanced guilt/penalty-phase concerns; defendant participated in selection	Denied — counsel’s strategy reasonable; no prejudice shown
Failure to challenge in- and out-of-court IDs / consult eyewitness expert	Counsel was deficient for not filing suppression motions and not using an ID expert	Counsel reasonably attacked IDs at trial; witnesses, collateral cases, and counsel’s cross-examination undercut misidentification; expert would be cumulative	Denied — no deficient performance or prejudice; reasonable strategy to challenge IDs before jury
Ineffective assistance of appellate counsel (habeas)	Appellate counsel misstated Peterson was convicted in three collateral robberies, undermining appellate process	Counsel erred factually, but the trial court’s independent clear-and-convincing findings on collateral crimes removed any prejudice	Denied — deficiency found but no prejudice; habeas denied

Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective assistance standard)
Carratelli v. State, 961 So.2d 312 (Fla. 2007) (actual juror bias standard for cause challenges)
Maharaj v. State, 778 So.2d 944 (Fla. 2000) (strategic choice not to file suppression motion can be reasonable)
Schoenwetter v. State, 46 So.3d 535 (Fla. 2010) (standards for appellate ineffective-assistance claims)
Johnson v. State, 438 So.2d 774 (Fla. 1983) (abuse-of-discretion standard for admitting eyewitness ID expert testimony)
Simmons v. State, 934 So.2d 1100 (Fla. 2006) (discussion on eyewitness ID evidence and expert testimony)
State v. Guilbert, 49 A.3d 705 (Conn. 2012) (eyewitness-ID experts generally admissible; scientific research on unreliability)
State v. Clopten, 223 P.3d 1103 (Utah 2009) (admit eyewitness-ID expert when evidentiary rules satisfied)
State v. Lawson, 291 P.3d 673 (Or. 2012) (traditional safeguards may be inadequate; experts can assist jurors)