King v. State
89 So. 3d 209
Fla.2012Background
- King was convicted of Denise Amber Lee’s first-degree murder, kidnapping, and involuntary sexual battery, with life-and-death sentencing procedures proceeding in Florida court.
- Lee was abducted from her home, transported, coerced, sexually assaulted, and murdered by King, who was identified at various points by eyewitnesses and forensic evidence.
- A 911 call captured Lee’s pleas as King drove her to an undisclosed location where she was later found shot and dead; evidence linked King to the Camaro, the shovel, duct tape, and DNA from Lee.
- Police and witnesses linked King to the crime through multiple strands of physical evidence (hair, DNA, blood, semen on clothing and items) and eyewitness identifications.
- The jury recommended death by a 12–0 vote; the trial court found four aggravating factors and two statutory mitigating factors, along with numerous nonstatutory mitigators, and imposed death.
- This direct appeal challenges evidentiary rulings, trial-course conduct, and the proportionality of the death sentence, with the Florida Supreme Court affirming the convictions and sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Cross-examination limitations on Salvador | Salvador’s inconsistent statements should have been explored | Limitations were proper; no good-faith basis for admission | No abuse of discretion; limitations proper |
| Prosecutor’s closing shifting burden | Prosecution improperly urged defense to prove innocence | Prosecutor’s statements were permissible rebuttal | Not an abuse of discretion; statements permissible rebuttal |
| Admission of firing-range shell casings | Casings relevant to illustrate the sequence and context | Casings were irrelevant or prejudicial | Evidence properly admitted as relevant to the crime sequence |
| Peremptory strike of minority juror | Strike lacked race-neutral basis or pretext evidence | Reason was race-neutral and genuine | Strike upheld; no pretext shown |
Key Cases Cited
- Holmes v. South Carolina, 547 U.S. 319 (U.S. 2006) (limits on defense evidence; substantial discretion to exclude irrelevant material)
- Crane v. Kentucky, 476 U.S. 683 (U.S. 1986) (right to present a complete defense within reasonable limits)
- Cohen v. State, 581 So.2d 926 (Fla. 3d DCA 1991) (need a factual link to the crime for third-party accusations)
- Gosciminski v. State, 994 So.2d 1018 (Fla. 2008) (new trial when questions lack good-faith basis)
- Johnson v. United States, 552 A.2d 513 (D.C. 1989) (clear link requirement for evidence against third party)