Dennis v. State, 109 So. 3d 680

Dennis was convicted of two counts of first-degree murder, burglary with a deadly weapon, and criminal mischief, and sentenced to death after a penalty phase with HAC and CCP aggravators.
On direct appeal, this Court upheld the convictions and death sentences; the U.S. Supreme Court denied certiorari.
After an initial postconviction motion, the trial court issued orders lacking findings; on remand, an evidentiary hearing was held and new claims were added.
Dennis alleged multiple ineffective-assistance claims during guilt and penalty phases, and claimed Brady violations, conflicts of interest, and improper evidentiary issues.
The postconviction court denied relief; on appeal, the Florida Supreme Court affirmed, and denied habeas relief.
The court also rejected claims about later public records requests and about lethal-injection protocol, finding no merit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Guilt-phase ineffective assistance	Dennis contends counsel failed to adequately prepare and investigate and to object to improper testimony.	Dennis argues counsel's performance fell outside reasonable standards and prejudiced the outcome.	No relief; claims lack specific prejudice and fail Strickland prongs.
Penalty-phase ineffective assistance	Dennis claims counsel failed to investigate/present mitigation evidence that could outweigh aggravation.	Defense investigation was reasonable; evidence wouldn’t have changed the outcome.	No relief; mitigating evidence did not create reasonable probability of a different sentence.
Brady violation (withheld evidence)	State suppressed memo to Dr. Rao that allegedly coached penalty-phase testimony.	No material prejudice; other evidence supported aggravators independently.	No relief; suppression not material to outcome.
Conflict of interest	Counsel’s workload and conflicts affected representation.	No actual conflicting interests identified; claim is speculative.	No relief; no actual conflict shown.
Appellate/other claims and procedural bars	Appellate counsel failed to raise certain claims; juror bias and confrontation issues discussed.	Claims are procedurally barred or meritless; not preserved or not fundamental error.	No relief; claims either procedurally barred or lacking prejudice.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance)
Porter v. McCollum, 558 U.S. 30 (U.S. 2010) (mitigation under penalty phase reviewed in totality of evidence)
Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (investigation into mitigation in capital cases must be reasonable)
Strickler v. Greene, 527 U.S. 263 (U.S. 1999) (materiality and prejudice in Brady contexts)
Cuyler v. Sullivan, 446 U.S. 335 (U.S. 1980) (actual conflict of interest requires showing adverse effect)
Jones v. Moore, 794 So.2d 579 (Fla. 2001) (preservation and prejudice considerations in appellate claims)
Valle v. Moore, 837 So.2d 905 (Fla. 2002) (fundamental error and preservation standards in appellate review)
Robinson v. State, 707 So.2d 688 (Fla. 1998) (procedural bars and scope of postconviction relief)
Tompkins v. State, 994 So.2d 1072 (Fla. 2008) (public records and lethal injection procedure considerations)
Guzman, 697 So.2d 1263 (Fla. 3d DCA 1997) (discovery violations and speedy trial prejudice standards)