Dwayne F. White v. State of Florida
214 So. 3d 541
| Fla. | 2017Background
- Victim Sarah Rucker was stabbed to death; Dwayne White (defendant) was convicted of first-degree murder after evidence placed him at the scene and his palm print was found in the victim’s blood.
- Earlier that night White had an altercation at the victim’s home and took her phone; phone records show calls between White and the victim and movements toward the murder site before the body was found.
- White had three prior violent felony convictions decades earlier and a history of domestic violence with this victim; he testified he found the body and fled because he distrusted police.
- At trial the jury recommended death by an 8–4 vote; the trial court found two aggravators (prior violent felony and HAC) and multiple mitigators (all given little weight) and imposed death.
- On appeal White challenged sufficiency of the evidence, the HAC instruction, disproportionality, and sought Hurst relief; the Court affirmed the conviction but vacated the death sentence and remanded for a new penalty phase due to Hurst error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for first-degree murder | State: circumstantial evidence (phone records, palm print, prior violence, timeline) proves guilt beyond reasonable doubt | White: theory that he arrived after the murder; another lover may have killed victim; evidence does not exclude that hypothesis | Affirmed conviction — circumstantial evidence inconsistent with White’s innocence theory and supports guilt |
| Hurst error (jury findings/unanimity) | White: Hurst requires unanimous jury findings; his advisory 8–4 recommendation and no unanimous findings violated Hurst and require relief | State: either no Hurst error or, if error, it was harmless beyond a reasonable doubt | Death sentence vacated; Hurst error not harmless beyond a reasonable doubt; remand for new penalty phase |
| Harmless-error vs. structural error under Hurst | White: alternatively argues Hurst error is structural and not subject to harmless-error review | State: Hurst error is subject to harmless-error review and was harmless here | Court applied harmless-error standard but found error not harmless; did not adopt structural-error claim |
| HAC instruction constitutionality (raised but not resolved) | White: HAC instruction unconstitutional | State: instruction valid | Not addressed (court did not reach penalty-phase issues beyond Hurst because Hurst required remand) |
Key Cases Cited
- Hurst v. State, 202 So. 3d 40 (Fla. 2016) (Florida decision requiring unanimous jury findings and unanimous recommendation for death)
- Hurst v. Florida, 136 S. Ct. 616 (U.S. 2016) (U.S. Supreme Court decision rejecting Florida procedure that allowed judge-alone factfinding to impose death)
- Hodgkins v. State, 175 So. 3d 741 (Fla. 2015) (circumstantial-evidence sufficiency decision; distinguished where defendant’s presence and history of animosity were lacking)
- Simmons v. State, 934 So. 2d 1100 (Fla. 2006) (standard for assessing sufficiency of the evidence and circumstantial-evidence review)
- Griffith v. Kentucky, 479 U.S. 314 (U.S. 1987) (new rules apply to cases pending on direct review)