James Daniel Turner v. State of Florida, 143 So. 3d 408

Turner was convicted by a jury in 2007 of first-degree murder and related crimes, resulting in a death sentence for the Howard murder after aggravating factors were found and weighed by the trial court.
Direct appeal affirmed the convictions and sentences; the U.S. Supreme Court denied certiorari in 2010.
Turner filed a 3.851 postconviction motion in 2011 asserting ten claims, chiefly ineffective assistance of counsel at the penalty phase and various constitutional challenges to the death penalty.
An evidentiary hearing was held on Claim 3, with testimony from Turner’s trial counsel, family, a mitigation specialist, and multiple medical/psychological experts for both sides.
The postconviction court granted an evidentiary hearing on Claim 3, denied the other claims, and later the circuit court denied relief, which this Court affirmed.
The Florida Supreme Court applied a mixed standard of review, deferring to the postconviction court’s factual findings while reviewing legal conclusions de novo, and concluded no reversible error occurred.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance of penalty-phase counsel	Turner asserts counsel were deficient for failing to present certain mitigating evidence and expert testimony	State contends trial strategy and investigations were reasonable under Strickland	No deficient performance; strategy reasonable and evidence adequately investigated
Cumulative error and failure to present mitigation evidence via family	Turner argues cumulative errors and lack of family cooperation compromised mitigation	State argues family uncooperativeness was established and testimony would not have changed outcome	Not satisfied; no prejudice shown from alleged mitigation omissions
Constitutional challenges to Florida death-penalty scheme	Turner challenges the death penalty statute as applied and as to aggravating/mitigating weighing, Ring/APPrendi related issues	State maintains claims are waived, procedurally barred, or meritless	Claims either waived, procedurally barred, or meritless

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong standard for ineffective assistance)
Caldwell v. Mississippi, 472 U.S. 320 (U.S. 1985) (rejected advisory jury posture as unconstitutional)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (limits sentencing facts to those proven beyond a reasonable doubt)
Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (requires jury find aggravating factors permitting death sentence)
Proffitt v. Florida, 428 U.S. 242 (U.S. 1976) (informs federal review of state death-penalty procedures)
Cox v. State, 966 So.2d 337 (Fla. 2007) (analyzes postconviction factual findings and deference to trial court)
Lukehart v. State, 70 So.3d 503 (Fla. 2011) (procedural bar and efficacy of cumulative-error claims)
Israel v. State, 985 So.2d 510 (Fla. 2008) (cumulative-error framework and merit review in Florida)
Heath v. State, 3 So.3d 1017 (Fla. 2009) (conveys requirements for preserving cumulative-error claims)
Spencer v. State, 615 So.2d 688 (Fla. 1993) (Spencer hearing context for mitigation evidence)
Hurst v. State, 18 So.3d 975 (Fla. 2009) (death-sentencing guidance and reliability concerns)
Turner v. Florida, 131 S. Ct. 426 (U.S. 2010) (denial of certiorari on direct appeal)