Kevin G. Jeffries, Jr. v. State of Florida
222 So. 3d 538
| Fla. | 2017Background
- Victim Wallace Scott, age 90, was found dead in his home after being bound, beaten, tortured, and strangled; scene showed heavy use of bleach and signs of ransacking.
- Kevin G. Jeffries Jr., David Challender (codefendant), and Ashley Griffin (codefendant) traveled from Atlanta to Panama City to rob Scott; gloves and zipties were purchased the day of the crime.
- Physical and DNA evidence tied Jeffries and the group to the scene (mixed DNA on a torn glove tip, Scott's blood on items in Griffin's car, blood/handler DNA on cords and scissors); Griffin cooperated and testified for the State after pleading guilty to lesser charges.
- Jeffries admitted participating in the burglary and restraining/assaulting Scott but disputed being the principal killer; medical testimony attributed death to strangulation plus blunt injuries.
- Jury convicted Jeffries of first-degree murder (premeditated and felony murder), armed burglary, and armed robbery; jury recommended death 10–2. Trial court found aggravators (burglary/robbery, HAC, CCP, victim vulnerability) and mitigators, and imposed death.
- On direct appeal the Florida Supreme Court affirmed convictions but vacated the death sentence under Hurst v. Florida and remanded for a new penalty phase.
Issues
| Issue | Jeffries' Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for convictions | Convictions not contested on appeal | Evidence (DNA, admissions, witness testimony) sufficient | Convictions affirmed — competent, substantial evidence supports premeditated and felony-murder theories |
| CCP and vulnerable-victim aggravators | Trial court erred in instruction/finding (challenged) | Aggravators supported by facts (planning, torture, victim age) | Court found aggravators proven; did not reverse those findings |
| Relative culpability / proportionality (codefendant plea) | Death disproportionate because Challender was more culpable but received life via plea | Plea-based disparate sentences not subject to relative-culpability review here | Majority: trial court properly declined relative-culpability review; proportionality upheld; concurrence would have reduced sentence to life |
| Hurst v. Florida (jury unanimity on aggravators) | Death sentence unconstitutional because jury did not unanimously find aggravators | State argued error harmless or that felony convictions supplied necessary findings | Court: Hurst error occurred (10–2 recommendation); not harmless beyond a reasonable doubt; death sentence vacated; new penalty phase ordered |
Key Cases Cited
- Brown v. State, 143 So.3d 392 (Fla. 2014) (standard for reviewing sufficiency of evidence and appellate duty)
- Blake v. State, 972 So.2d 839 (Fla. 2007) (evidentiary sufficiency standard citations)
- Crain v. State, 894 So.2d 59 (Fla. 2004) (affirmation when at least one murder theory supported)
- Hurst v. State, 202 So.3d 40 (Fla. 2016) (Florida precedent requiring jury unanimity for findings supporting death)
- Ring v. Arizona, 536 U.S. 584 (2002) (jury must find facts increasing maximum punishment)
- McCloud v. State, 208 So.3d 668 (Fla. 2016) (relative culpability and review when plea produces disparate sentences)
- Lawrence v. State, 698 So.2d 1219 (Fla. 1997) (proportionality upheld with HAC and CCP aggravators)
- Ocha v. State, 826 So.2d 956 (Fla. 2002) (death proportionate where strangulation and other aggravators present)