Derral Wayne Hodgkins v. State of Florida, 175 So. 3d 741

Victim Teresa Lodge was found dead in her apartment on Sept. 28, 2006, with multiple stab wounds and evidence of manual strangulation; no murder weapon recovered and no defensive wounds on hands.
Hodgkins’s DNA was detected in material scraped from under Lodge’s left fingernails; FDLE reported the match about a year later and detectives interviewed Hodgkins, who gave multiple inconsistent statements about his last contacts with Lodge.
Forensics: DNA from the fingernail scrapings was described as “robust” (complete profile); expert testimony acknowledged routine contact or intimate contact can transfer DNA and that DNA persistence/degradation depends on many factors.
Crime-scene facts: apartment showed no forced entry, a hidden spare key was missing, a bloody beer bottle was recovered (but no prints linked to Hodgkins), and 18 unidentified fingerprints were lifted.
Procedural posture: Hodgkins was convicted of first-degree premeditated murder and sentenced to death after an August 2011 trial; this appeal challenges sufficiency of the circumstantial evidence supporting the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove Hodgkins committed murder	State: DNA under victim’s fingernails matches Hodgkins; his lies about contact indicate consciousness of guilt and he was likely the last person to touch her	Hodgkins: DNA transfer can occur during innocent prior contact; extensive hand‑washing and workplace hygiene make persistence unlikely; other persons had access via missing key	Reversed: evidence insufficient; circumstantial proof did not exclude reasonable hypothesis of innocence (someone else killed Lodge)
Premeditation	State: nature and manner of killing support premeditation	Defense: challenges nexus between Hodgkins and the killing	Court did not reach merits after finding insufficient evidence of homicide by Hodgkins (discussion limited to sufficiency)
Trial-court limitation on cross‑examination of prosecution witness	State contends limitation proper	Defense contends error	Raised on appeal but not dispositive of reversal (court limited analysis to sufficiency)
Shackling during penalty phase	State: security protocol justified restraints	Defense: visible restraints inherently prejudicial and required record inquiry; counsel objected	Concurring opinion: trial court erred by failing to conduct required on‑the‑record inquiry; reminder of proper standard (though majority reversal was based on insufficiency)

Dausch v. State, 141 So.3d 513 (Fla. 2014) (this Court independently reviews sufficiency in capital cases and reiterates circumstantial‑evidence standard)
Johnston v. State, 863 So.2d 271 (Fla. 2003) (states standard for viewing evidence in light most favorable to State and burden to exclude reasonable hypotheses of innocence)
Jaramillo v. State, 417 So.2d 257 (Fla. 1982) (special standard for convictions based wholly on circumstantial evidence)
Ballard v. State, 923 So.2d 475 (Fla. 2006) (reversal where forensic evidence only proved prior presence, not that defendant committed the murders)
State v. Law, 559 So.2d 187 (Fla. 1989) (State must introduce competent evidence inconsistent with defendant’s theory; jury decides reasonable hypotheses)
Darling v. State, 808 So.2d 145 (Fla. 2002) (clarifies State’s threshold burden in circumstantial cases)
Deck v. Missouri, 544 U.S. 622 (U.S. 2005) (visible shackling during trial is inherently prejudicial and must be justified by an essential state interest)