Eddie Wayne Davis v. State of Florida
142 So. 3d 867
| Fla. | 2014Background
- Davis, a death-row inmate, was convicted of first-degree murder of an 11-year-old girl, plus burglary with assault, kidnapping of a child, and sexual battery on a minor.
- Death penalty imposed after a unanimous jury recommendation; trial court found aggravators including ongoing imprisonment, during kidnapping/sexual battery, to avoid arrest, and heinous nature; mitigation included emotional disturbance and various nonstatutory factors.
- Davis pursued postconviction relief under Rule 3.851; the circuit court denied relief and Davis’s death warrant was signed for July 2014.
- Davis raised three post-warrant claims: (1) an as-applied challenge to Florida’s lethal-injection protocol (porphyria); (2) death-penalty ineligibility based on being the functional equivalent of a child; (3) clemency-proceedings due-process challenges.
- The Florida Supreme Court affirmed the circuit court’s denial of relief and denied a stay of execution, upholding the executive clemency framework and the evidentiary record supporting the court’s findings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| As-applied challenge to lethal injection porphyria | Davis contends porphyria makes midazolam unconstitutional for him | State argues midazolam renders unconsciousness before pain; evidence shows no substantial risk | denial affirmed; no substantial risk shown; Dr. Evans’ testimony admissible and credible |
| Death-penalty eligibility under Roper | Functional-equivalent-of-a-child theory with new brain-development evidence | Roper applies only to chronological under 18; evidence insufficient | claim rejected; Roper inapplicable to Davis |
| Clemency-proceedings due process | Procedural flaws: retired commissioner presence and pre-clemency communications | Clemency is executive, not judicial; discretion rests with Governor | claim rejected; clemency process upheld; no due-process violation |
Key Cases Cited
- Howell v. State, 133 So. 3d 511 (Fla. 2014) (Eighth Amendment heavy-burden standard for toxic/ill- effects of execution methods)
- Pardo v. State, 108 So. 3d 558 (Fla. 2012) (Must show substantial risk of serious harm; heavy burden on defendant)
- Marek v. State, 14 So. 3d 985 (Fla. 2009) (Newly discovered evidence requires two-prong test; not met here)
- Hill v. State, 921 So. 2d 584 (Fla. 2006) (Roper applicability limited to under-18 chronological age)
- Schoenwetter v. State, 46 So. 3d 535 (Fla. 2010) (Roper-based challenges and adult-age limitations)