Hall v. State, 107 So. 3d 262

Enoch Hall, an inmate at Tomoka Correctional Institute (TCI), was convicted of first-degree murder and sentenced to death for the stabbing death of Officer Donna Fitzgerald in the PRIDE facility.
Fitzgerald’s body was found in the paint room; she suffered blunt force trauma, multiple stab wounds, and a ligature-induced neck mark; a bloody T-shirt of Hall was found in a water bucket nearby.
Hall was apprehended by TCI personnel after fleeing; he repeatedly stated, I freaked out. I snapped. I killed her.
Multiple confessions were obtained from Hall (three statements to FDLE agents) during the night of the murder; the State offered cell/FDLE testimony and physical evidence connected Hall to the crime.
At trial, the State presented blood and DNA evidence linking Hall to the scene, including blood on clothing, a cap, and Speedy Dry granules with Fitzgerald’s DNA; defense argued evidentiary and constitutional issues.
During the penalty phase, the court admitted evidence of Hall’s prior violent felonies and heard mitigation and victim-impact testimony; the jury recommended death unanimously.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Hall’s confessions voluntary?	Hall contends coercion tainted statements.	Hall argues totality of circumstances shows coercion.	Voluntary; totality supported suppression denial.
Did Dr. Bulic’s sequencing testimony mislead on conviction or HAC/CCP?	Bulic’s sequence testimony misled jury about causation.	Testimony was not reversible error or misleading.	No reversible error; testimony not mislead on conviction or HAC.
Was admission of prior violent felonies during penalty phase proper?	Prior violent felonies are admissible to prove aggravation.	Such evidence risks undue prejudice and should be limited.	Admissible; not abused; detailed prior acts permitted proscribed by Franklin.
Was the CCP (cold, calculated, and premeditated) aggravator supported?	Evidence shows premeditation and calculated killing.	Under the totality, no clear CCP; findings were speculative.	CCP stricken; not supported by competent substantial evidence; harmless error.
Does Ring apply to Florida’s capital sentencing scheme in Hall’s case?	Ring requires jury finding of aggravators when they function as elements.	Ring does not apply to prior felonies or under-sentence aggravators here.	Ring does not apply; claim rejected.

Ramirez v. State, 739 So.2d 568 (Fla. 1999) (voluntariness standard for custodial confessions)
Anderson v. State, 863 So.2d 169 (Fla. 2003) (confessions must be free and voluntary)
State v. Outten, 206 So.2d 392 (Fla. 1968) (coercion continues unless isolated break shown)
Leon v. Wainwright, 734 F.2d 770 (11th Cir. 1984) (test for tainting of subsequent confessions)
Thomas v. State, 894 So.2d 126 (Fla. 2004) (credibility standard for suppression findings)
Cuervo v. State, 967 So.2d 155 (Fla. 2007) (deference to trial court on facts; de novo law application)
Connor v. State, 803 So.2d 598 (Fla. 2001) (de novo review of law; factual findings sustained if supported)
Franklin v. State, 965 So.2d 79 (Fla. 2007) (prior violent felony evidence admissibility in penalty phase)
Ray v. State, 755 So.2d 604 (Fla. 2000) (discretion in admitting evidence; standard of abuse)
Brooks v. State, 918 So.2d 181 (Fla. 2005) (prosecutorial closing arguments; preservation requirements)
Williams v. State, 37 So.3d 187 (Fla. 2010) ( CCP analysis; circumstantial evidence must negate alternatives)
Floyd v. State, 913 So.2d 564 (Fla. 2005) (proportionality review framework)