David James Martin v. State of Florida, 322 So.3d 25

Defendant David Martin was convicted of first-degree murder and armed robbery based largely on a videotaped confession and corroborating investigative evidence; convictions and death sentence affirmed on direct appeal in Martin v. State.
During voir dire one juror ("Smith") failed to disclose a 1992 DUI, a juvenile delinquency adjudication for sexual battery (1985), and that his grandmother murdered his grandfather; Smith served on the jury and later denied bias.
Martin filed successive postconviction motions under Fla. R. Crim. P. 3.851; postconviction discovery revealed Smith’s additional nondisclosures and led to an evidentiary hearing where Smith testified and trial counsel said he likely would have sought to excuse Smith if he had known.
The postconviction court granted a new penalty-phase hearing (Hurst error) but denied guilt-phase claims, applying the Jones newly-discovered-evidence test to the juror-misconduct claim and finding Martin failed to show probable acquittal on retrial.
The Florida Supreme Court reviewed whether the juror-misconduct claim was procedurally barred or untimely and clarified the proper standard for postconviction juror-misconduct claims; it affirmed denial of the juror-misconduct and all guilt-phase ineffective-assistance claims.

Issue	Martin's Argument	State's Argument	Held
Standard for postconviction juror-misconduct claims	The nondisclosure entitled him to relief under newly discovered-evidence or De La Rosa tests	Apply De La Rosa or Jones standards; deny relief	Apply Boyd’s actual-bias standard in postconviction context; De La Rosa and Jones are inappropriate here; must show actual juror bias to obtain relief
Procedural bar / timeliness	Facts were undiscoverable before direct appeal; claim filed within one year of disclosure	Claim should have been raised on direct appeal or is time-barred under R.3.851	Not barred: facts were undiscoverable with diligence so R.3.851(d)(2)(A) exception applies
Merits of juror-misconduct claim	Smith’s concealments (DUI, juvenile sexual battery, family murder) show juror dishonesty and denial of impartial jury	Smith credible at hearing; omissions not motivated by bias; no evidence of actual bias	Denied: trial court’s credibility/findings supported; Martin failed to prove actual juror bias
Ineffective-assistance claims (confession expert, cell-tower challenge, failure to call corroborating witnesses)	Counsel was deficient and prejudice resulted; evidentiary hearing warranted	Counsel’s performance within reasonable bounds; no reasonable probability of different outcome	Denied: summary denials affirmed—no deficient performance shown or no prejudice established

McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548 (1984) (voir dire nondisclosure framework)
Boyd v. State, 200 So. 3d 685 (Fla. 2015) (postconviction juror-misconduct claim requires proof of actual juror bias)
De La Rosa v. Zequeira, 659 So. 2d 239 (Fla. 1995) (three-part test for juror nondisclosure in direct-appeal context)
Jones v. State, 709 So. 2d 512 (Fla. 1998) (standalone newly discovered-evidence test requiring probable acquittal on retrial)
Carratelli v. State, 961 So. 2d 312 (Fla. 2007) (in IAC context, bias must be plain on face of voir dire record)
Martin v. State, 107 So. 3d 281 (Fla. 2012) (direct-appeal opinion upholding conviction and sentence)
Irvin v. Dowd, 366 U.S. 717 (1961) (right to impartial jury)
Smith v. Phillips, 455 U.S. 209 (1982) (remedy for juror partiality is a hearing)
Warger v. Shauers, 574 U.S. 40 (2014) (limits on juror testimony about deliberations)
Neder v. United States, 527 U.S. 1 (1999) (materiality standard explanation)