Donald Otis Williams v. State of Florida
209 So. 3d 543
| Fla. | 2017Background
- Victim Janet Patrick (81) disappeared after shopping on Oct. 18, 2010; her partially skeletonized nude remains were found days later in Polk County.
- Donald Otis Williams was seen with Patrick on surveillance, later found in her car with her credit cards; forensic evidence (blood in trunk, mixed DNA on clothing, semen in briefs) linked both to the vehicle and to Williams.
- Williams gave inconsistent statements, initially claiming both were abducted; he later recanted.
- A jury convicted Williams of robbery, kidnapping, and first-degree (felony) murder; during the penalty phase the jury’s special verdict unanimously found four aggravators but recommended death by a 9–3 vote.
- Trial court sentenced Williams to death after weighing aggravators (given great weight) against mitigators (some statutory and many nonstatutory mitigators given varying weight).
- On direct appeal the Florida Supreme Court affirmed guilt but reversed the death sentence under Hurst v. Florida / Hurst v. State because the jury did not unanimously find all facts necessary to impose death or unanimously recommend death; remanded for a new penalty phase.
Issues
| Issue | Williams’ Argument | State’s Argument | Held |
|---|---|---|---|
| Continuance after reappointment of counsel | Reappointment late in guilt phase denied counsel adequate time to prepare (especially for DNA disclosures) | Short continuance was granted; no undue prejudice shown; delay was of Williams’ own making | No abuse of discretion; denial of further continuance not reversible error |
| Medical examiner testimony | Dr. Wolf exceeded expertise and invaded jury province by opining manner of death was homicide | Opinion was based on autopsy, records, photos, anthropology consult—proper expert assistance to jury | No fundamental error; testimony admissible and did not usurp jury role |
| References to criminal past & prosecutorial comments | Multiple remarks and innuendo (uncharged sexual battery; appeals to victim justice) prejudiced trial | Some remarks were brief/contextual; jury already aware of some criminal history; comments not objectively outcome-determinative | Some remarks improper (e.g., victim-justice appeals, sexual innuendo) but did not amount to fundamental error or require new guilt phase |
| Hurst/Ring constitutional challenge to death sentence | Williams: Florida scheme violated Sixth Amendment (jury unanimity); death sentence invalid under Hurst and requires relief | State: either no error or any error was harmless beyond a reasonable doubt | Hurst error occurred (jury did not unanimously find sufficiency/outweighing; death recommendation was 9–3); error not harmless; vacated death sentence and remanded for new penalty phase |
Key Cases Cited
- Hurst v. Florida, 136 S. Ct. 616 (2016) (Sixth Amendment requires jury, not judge, to find facts necessary for death sentence)
- Hurst v. State, 202 So.3d 40 (Fla. 2016) (Florida Supreme Court: jury must unanimously find each aggravator, sufficiency, and that aggravators outweigh mitigation; jury’s death recommendation must be unanimous)
- Ring v. Arizona, 536 U.S. 584 (2002) (jury must find aggravating factors that expose defendant to death)
- DiGuilio v. State, 491 So.2d 1129 (Fla. 1986) (harmless-error standard and burden on State to prove error did not contribute to result)
- Geralds v. State, 674 So.2d 96 (Fla. 1996) (medical examiner may base opinion on autopsy, records, photos, and other objective materials)