James Aren Duckett v. State of Florida, SC16-793

In 1988 James Aren Duckett was convicted of first-degree murder and sexual battery; conviction and death sentence were affirmed on direct appeal.
At trial FBI analyst Michael Malone testified that a pubic hair found in the victim’s underpants was consistent with Duckett’s pubic hair and inconsistent with others; his testimony was extensively cross-examined and rebutted by a state expert.
Postconviction proceedings produced critical reviews of Malone’s work: a 2011 independent report and a 2014 Department of Justice (DOJ) review (based partly on a 2014 FBI review) concluding some of Malone’s statements exceeded scientific limits.
Duckett filed a second successive Rule 3.851 motion asserting (1) newly discovered evidence based on the 2014 DOJ Review, (2) Brady and (3) Giglio violations, and (4) cumulative error; the circuit court summarily denied relief.
The Florida Supreme Court reviewed the summary denial de novo and affirmed, holding the new reports did not render Malone’s testimony false in context, the State did not suppress material evidence, and any erroneous statements were not shown to be Giglio-material or dispositive given the strong non-hair evidence (e.g., fingerprints, tire tracks, last-seen facts).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Newly discovered evidence	2014 DOJ Review shows Malone’s trial testimony was false/invalid and would probably produce acquittal	Malone’s testimony, in full context, was not shown to be false; hair evidence was corroborated and not dispositive; field not discredited	Denied — new evidence would not probably produce acquittal
Brady	State withheld material/exculpatory information about Malone’s analysis	No evidence prosecutors knew of or suppressed problems with Malone’s work	Denied — no competent evidence of suppression
Giglio	Prosecutor knowingly presented false testimony via Malone	Duckett failed to prove Malone’s testimony was false or that prosecutors knew it was false	Denied — first prong (falsity) not established
Cumulative error	Errors shown cumulative warrant new guilt phase	Individual claims are barred/meritless so cumulative claim fails; prior rejections cannot be re-litigated	Denied — no cumulative prejudice shown

Duckett v. State, 568 So. 2d 891 (Fla. 1990) (direct appeal describing Malone’s trial testimony)
Duckett v. State, 918 So. 2d 224 (Fla. 2005) (postconviction history and evidentiary summary)
Duckett v. State, 148 So. 3d 1163 (Fla. 2014) (prior successive-motion decision addressing 2011 report)
Marek v. State, 14 So. 3d 985 (Fla. 2009) (two-prong newly discovered evidence test)
Hildwin v. State, 141 So. 3d 1178 (Fla. 2014) (consider newly discovered evidence with all admissible evidence at retrial)
Jimenez v. State, 997 So. 2d 1056 (Fla. 2008) (timeliness rule for successive 3.851 motions)
Davis v. State, 136 So. 3d 1169 (Fla. 2014) (Brady elements)
Guzman v. State, 868 So. 2d 498 (Fla. 2003) (Giglio elements)
Kormondy v. State, 154 So. 3d 341 (Fla. 2015) (de novo review of summary denial of successive 3.851 motion)
Brady v. Maryland, 373 U.S. 83 (1963) (prosecutor’s duty to disclose exculpatory evidence)
Giglio v. United States, 405 U.S. 150 (1972) (impeachment material and prosecutor knowledge standard)