Kim Jackson v. State of Florida
180 So. 3d 938
| Fla. | 2015Background
- Victim Debra Pearce was found stabbed to death in her kitchen in October 2004; crime scene showed multiple stab wounds (including fatal neck and chest wounds), defensive injuries, two knives at scene, blood spatter, a bloody fingerprint on the sink lip, and a dark hair on the victim’s calf.
- DNA from the hair matched Kim Jackson; a latent print in blood on the sink was matched by two experts to Jackson’s right ring finger; another knife contained mixed DNA not matching Jackson.
- Jackson asserted an alibi that he was in Adel, Georgia, for his birthday the weekend of the murder and denied knowing Pearce; family and friends testified to his alibi.
- The jury convicted Jackson of first-degree premeditated murder and, after a penalty phase finding three aggravators (two prior violent felonies, on felony probation, and HAC), recommended death 8–4; the trial court sentenced him to death.
- On direct appeal, Jackson challenged sufficiency of the circumstantial evidence (timing/identity of the fingerprint and hair), whether he was an active participant, HAC application, proportionality, and constitutional challenges under Ring/Enmund/Tison.
Issues
| Issue | Jackson's Argument | State's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence (circumstantial) | Alibi and that fingerprint/hair could have been left earlier or transferred; evidence does not exclude reasonable hypotheses of innocence | Hair DNA and blood-transfer fingerprint place Jackson at scene during attack; physical evidence of struggle and inconsistencies in Jackson’s statements | Conviction affirmed: cumulative circumstantial evidence (bloody transfer print + forcibly removed hair + defensive wounds + credibility issues) sufficient for jury to reject alibi |
| Fingerprint identity/timing | Latent print was not of value/timing uncertain; could have been left earlier and later coated by blood | Two qualified latent-print examiners matched print to Jackson and testified the print was a transfer made while finger was coated in wet blood | Held that expert testimony supported identification and timing (blood-transfer), and no affirmative evidence showed it was preexisting; jury could credit State’s experts |
| Active participation / principal liability | Even if present, Jackson may not have been an active participant (another person may have killed Pearce) | Forcibly removed hair and bloody transfer print indicate struggle and Jackson’s physical involvement; jury instructed on principals and found Jackson played a significant role | Court affirmed that evidence supports that Jackson was a direct/active participant; principal instruction and jury findings sustain conviction and HAC |
| HAC vicarious application & proportionality; Ring/Enmund/Tison challenge | HAC applied vicariously/Enmund/Tison proportionality concerns and Ring Sixth Amendment challenge to sentencing | Evidence showed Jackson was particularly physically involved; case tried as premeditated murder (not felony murder); Florida precedent allows current capital scheme | HAC upheld on the facts; death sentence found proportionate; court declines to revisit Ring/Apprendi precedent as applied in Florida |
Key Cases Cited
- Twilegar v. State, 42 So. 3d 177 (Fla. 2010) (circumstantial-evidence standard requiring inconsistency with reasonable hypotheses of innocence)
- Ballard v. State, 923 So. 2d 475 (Fla. 2006) (fingerprint/hair evidence alone may be insufficient where evidence consistent with innocent explanations)
- Darling v. State, 808 So. 2d 145 (Fla. 2002) (combined fingerprint and DNA evidence can be sufficient to rebut innocent hypotheses)
- Perry v. State, 801 So. 2d 78 (Fla. 2001) (multiple, forceful stab wounds and defensive injuries support premeditation)
- Enmund v. Florida, 458 U.S. 782 (U.S. 1982) (limiting death penalty for minor participants in felony murder without requisite mental state)
- Tison v. Arizona, 481 U.S. 137 (U.S. 1987) (extending Enmund analysis to major participants with reckless indifference)
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (Apprendi-related decision on jury findings for death eligibility)
- Perez v. State, 919 So. 2d 347 (Fla. 2005) (Enmund/Tison concerns when HAC applied vicariously)
- Duest v. State, 855 So. 2d 33 (Fla. 2003) (proportionality analysis comparing aggravators and mitigators in stabbing cases)
- Abdool v. State, 53 So. 3d 208 (Fla. 2010) (affirming death where multiple aggravators outweigh numerous mitigators)