Jennings v. State, 123 So. 3d 1101

Jennings killed three Cracker Barrel workers during a 1995 robbery in Naples; he was death-sentenced after a trial; direct appeal affirmed convictions and sentences.
He filed a March 2000 Rule 3.850 postconviction motion with multiple claims, later amended; an evidentiary hearing was held on five claims.
Postconviction court denied relief after a three-day evidentiary hearing.
Jennings also filed a petition for writ of habeas corpus seeking relief based on appellate counsel performance.
The Court affirms the postconviction court’s denial of relief and denies Jennings’ habeas petition.
The ruling discusses Strickland standards, specific mitigation investigations, and impeachment and evidentiary issues in depth.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Penalty-phase mitigation effectiveness	Jennings argues trial counsel failed to pursue or present adequate mental health and background mitigation.	Counsel made reasonable strategic decisions not to present mitigating evidence likely to harm; experts’ evaluations were probative but not decisive.	Denied; trial counsel’s strategy was reasonable and not deficient.
Impeachment of Cheney (State witness)	Counsel failed to adequately prepare for cross-examining Cheney and to probe relationships/motives.	Cross-examination limitations were insufficient to undermine credibility.	Denied; no prejudice to confidence in guilt/penalty verdicts.
Summary denial of claims in 3.850 motion	Multiple claims deserved evidentiary hearings or more thorough consideration.	Claims were procedurally barred or legally insufficient.	Affirmed; summary denial upheld.
Admissibility/advisability of post-arrest statements challenge on appeal	Counsel should have challenged admissibility and reliability of Jennings’ statements.	Not adequately developed on appeal; insufficient prejudice shown.	Denied; insufficient prejudice shown.

Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes two-prong standard for ineffective assistance of counsel)
Sexton v. State, 997 So.2d 1073 (Fla. 2008) (duty to investigate mitigation; reasonable strategic decisions)
Gaskin v. State, 822 So.2d 1243 (Fla. 2002) (counsel’s strategy may be reasonable even if evidence could help defendant)
Winkles v. State, 21 So.3d 19 (Fla. 2009) (no deficiency where evidence would open door to harm; strategic choice respected)
Porter v. McCollum, 130 S. Ct. 447 (2010) (penalty-phase prejudice standard; not requiring more likely than not)
Hurst v. State, 18 So.3d 975 (Fla. 2009) (standard for prejudice in criminal sentencing contexts)