Leo L. Boatman v. State of Florida, 402 So.3d 900

Background

Leo L. Boatman was convicted of first-degree premeditated murder and sentenced to death for killing fellow inmate William L. Chapman at Florida State Prison in 2019; he was already serving life sentences for unrelated murders.
The attack, coordinated with codefendant William E. Wells, was committed in the prison dayroom using shanks and a ligature, and lasted about 12 minutes, during which correctional officers were prevented from intervening.
The incident was motivated by Boatman and Wells’s frustration at being denied reduced confinement status, and by perceived threats or disrespect from the victim; the murder was premeditated and captured on video.
At trial, Boatman’s defense focused on diminished capacity, heat of passion, provocation, or self-defense, highlighting his traumatic upbringing and mental health history, including severe childhood abuse and neuropsychiatric impairments.
The jury convicted Boatman, and the sentencing judge found several aggravating factors, outweighing Boatman’s extensive mitigation evidence; Boatman appealed on multiple grounds.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Competence to proceed	Boatman argued he was incompetent to proceed based on Dr. Werner’s opinion.	State argued Boatman’s own conduct and Dr. Werner’s findings supported competence.	Competence was sufficiently established; denial of motion affirmed.
Disqualification of judge	Judge’s comments showed bias, depriving him of fair trial.	Judge’s comments only reflected case-management frustration, not bias.	No reasonable fear of bias; denial affirmed.
Exclusion of crime-scene evidence	Videos/photos were inflammatory and unnecessary.	Evidence was relevant and highly probative.	Video and photos were admissible as relevant evidence.
Sufficiency of evidence for premeditation	Evidence did not prove premeditation; no justified jury instruction for manslaughter variant.	Attack was planned; Boatman’s admissions and conduct proved premeditation.	Evidence was sufficient; denial of acquittal motion affirmed.
Waiver of penalty-phase jury	Waiver was not knowing, intelligent, or voluntary due to mental illness.	Boatman’s decision was made after thorough colloquy and understanding of rights.	Waiver valid and voluntary.
Jury selection/procedural fairness	Voir dire and jury selection were unfair, including denial of additional peremptory challenges.	Jury procedures followed established legal standards; defense granted peremptory when needed.	No prejudice shown; process upheld.
Florida’s death penalty statute	Statute is unconstitutional, fails to narrow class of death-eligible defendants.	Statute is valid under Florida and federal law.	Previously rejected, no merit to constitutional challenge.

Key Cases Cited

Hurst v. Florida, 577 U.S. 92 (2016) (jury necessary to find aggravating factors for death penalty)
Godinez v. Moran, 509 U.S. 389 (1993) (competence to plead guilty same as competence for trial)
Atkins v. Virginia, 536 U.S. 304 (2002) (prohibits execution of intellectually disabled offenders)
Roper v. Simmons, 543 U.S. 551 (2005) (prohibits execution of juveniles)
Lowenfield v. Phelps, 484 U.S. 231 (1988) (Eighth Amendment requires narrowing of death-eligible offenses)
Bolin v. State, 736 So. 2d 1160 (Fla. 1999) (voir dire on pretrial publicity)
Smith v. State, 28 So. 3d 838 (Fla. 2009) (test for admissibility of photographs in criminal cases)
Carrizales v. State, 356 So. 2d 274 (Fla. 1978) (jury instruction on unnecessary killing to prevent unlawful act)
Franklin v. State, 965 So. 2d 79 (Fla. 2007) (elements required for finding cold, calculated, and premeditated aggravator)
Francis v. State, 808 So. 2d 110 (Fla. 2001) (heinous, atrocious and cruel aggravator definition)
King v. State, 130 So. 3d 676 (Fla. 2013) (HAC requires awareness of impending death)
Barnhill v. State, 834 So. 2d 836 (Fla. 2002) (strangulation as HAC)
Lawrence v. State, 308 So. 3d 544 (Fla. 2020) (Florida ended comparative proportionality review)