Coleman v. State, 64 So. 3d 1210

Coleman was convicted of four counts of first-degree murder and one count of attempted first-degree murder; the jury recommended life by a 6–6 verdict, and the trial court overridden the verdict to impose four death sentences.
On direct appeal, the Florida Supreme Court affirmed the convictions and death sentences, upholding the override under Tedder despite the absence of mitigation.
Coleman filed multiple Rule 3.850 postconviction motions alleging ineffective assistance of penalty-phase counsel for failing to investigate and present mitigating evidence.
An evidentiary hearing in 2001 revealed substantial mitigation (poverty, unstable childhood, abuse, head injury, mental health issues, substance abuse) that trial counsel failed to investigate.
The postconviction court denied relief; on review, the Florida Supreme Court reversed in part, holding trial counsel deficient for failing to investigate mitigation and that the deficiency prejudiced the penalty-phase proceeding.
The Courtvacated the death sentences, remanding for imposition of life sentences without an additional resentencing proceeding before a judge or jury, and denied habeas relief on non-penalty claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether penalty-phase counsel’s investigation was deficient under Strickland	Coleman	Stokes failed to investigate mitigation; relied on alibi defense	Yes; deficient investigation established
Whether the deficiency prejudiced the penalty outcome	Coleman	Mitigation would not have changed the judge’s override	Yes; mitigation would have provided a reasonable basis for life
Appropriate remedy for a successful penalty-phase ineffectiveness claim	Coleman	Remand for resentencing before judge or jury	Remand for imposition of life sentences without further resentencing; no new sentencing proceeding required
Whether failure to pursue mental-health evaluation was ineffective	Coleman	No need for mental health expert	Yes; failure to obtain mental-health evidence contributed to prejudice

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong deficient performance and prejudice test; highly deferential review)
Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (duty to investigate mitigation; reasonableness of investigation assessed under totality of circumstances)
Rom pilla v. Beard, 545 U.S. 374 (U.S. 2005) (requires reasonable investigation into defendant’s background for mitigation)
Williams v. State, 987 So.2d 1 (Fla. 2008) (limits prejudice analysis to whether mitigation would provide a reasonable basis for life)
Tedder v. State, 322 So.2d 908 (Fla. 1975) (jury override standard; great weight to life recommendation)
Hall v. State, 541 So.2d 1125 (Fla. 1989) (reaffirms focus on the jury’s life recommendation in Tedder analyses)
Stevens v. State, 552 So.2d 1082 (Fla. 1989) (mitigation evidence must be considered in light most favorable to defendant on life recommendation)
Hannon v. State, 941 So.2d 1109 (Fla. 2006) (requires reasonable mitigation investigation in Florida death-penalty cases)