Hall v. State
87 So. 3d 667
Fla.2012Background
- Hall was sentenced to death for the September 2006 murder of Anthony Blunt and was convicted of multiple felonies including armed burglary and armed robbery.
- The crime involved Hall and accomplices entering a party, shooting numerous attendees, and stealing jewelry and cash.
- Eyewitnesses identified Hall as the first shooter and the controller of the robbery, with communication between Hall and Angel Glenn before and after the robbery.
- The victims included Blunt (killed) and Evans (killed), with several others shot and injured during a ten-minute ambush.
- During penalty, expert testimony showed Hall had low intelligence and histories of substance abuse; the jury found three aggravators and one HAC beyond a reasonable doubt, and recommended death for Blunt and life for Evans.
- The court conducted a Spencer hearing, weighed aggravators and mitigators, and followed the jury’s recommendation for Blunt’s death, while also addressing proportionality and sufficiency on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| HAC applicability to Blunt murder | Hall argues HAC not supported by evidence | State asserts sufficient evidence supports HAC | HAC upheld; evidence showed Blunt suffered and fate inflicted with indifference |
| Proportionality of death sentence | Death sentence disproportionate given mitigators | State argues proportionality satisfied by factors and comparable cases | Death sentence proportionate under totality of circumstances |
Key Cases Cited
- Aguirre-Jarquin v. State, 9 So.3d 593 (Fla. 2009) (trial court must instruct on credible aggravators; standard of review competent substantial evidence)
- Barnhill v. State, 834 So.2d 836 (Fla. 2002) (HAC focuses on the murder’s torture and the defendant’s indifference or enjoyment of suffering)
- Lynch v. State, 841 So.2d 362 (Fla. 2003) (victim’s fear/awareness can inform HAC analysis)
- Guzman v. State, 721 So.2d 1155 (Fla. 1998) (HAC may be found where victim’s suffering is evident to justify torturous death)
- Teffeteller v. State, 439 So.2d 840 (Fla. 1983) (death by shooting alone may not establish HAC absent intent to torture)
- Buckner v. State, 714 So.2d 384 (Fla. 1998) (HAC not established where no evidence defendant intended prolonged suffering)
- Dixon v. State, 283 So.2d 1 (Fla. 1973) (original strict definition of HAC; requires torture or extreme indifference)
- Lewis v. State, 398 So.2d 432 (Fla. 1981) (shooting deaths not automatically HAC)
- McGirth v. State, ~So.3d 795 (Fla. 2010) (HAC supported by competent substantial evidence in appropriate circumstances)