Lucas v. Secretary, Department of Corrections
682 F.3d 1342
11th Cir.2012Background
- Lucas was convicted in Florida of first‑degree murder for Jill Piper’s death and two counts of attempted first‑degree murder for Rice and Byrd, and was sentenced to death for Piper’s murder.
- Florida direct and collateral appeals led to a series of remands and resentencings; the final direct/ collateral proceedings upheld the death sentence.
- During trial, the state introduced Deputy Boyette as an undisclosed rebuttal witness; no pretrial disclosure or inquiry was conducted.
- A 1987 resentencing before a new jury resulted in another death sentence after the prosecution exercised peremptory challenges against jurors with anti‑death‑penalty reservations.
- Lucas argued several post‑conviction claims, including ineffective assistance of counsel and improper use of peremptory challenges; the district court denied relief.
- On review under AEDPA, the Eleventh Circuit affirmed, applying deference to state court findings and addressing exhaustion and merits arguments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether admitting an undisclosed rebuttal witness violated law | Lucas | Lucas | Claim exhausted but meritless |
| Whether trial counsel's failure to cite discovery authority was ineffective assistance | Lucas | Lucas | Procedurally barred; merits fail |
| Whether failure to identify drug ingested affected 1987 resentencing | Lucas | Lucas | Not prejudicial; Strickland not satisfied |
| Whether resentencing counsel failed to negate HAC aggravator | Lucas | Lucas | No reversible error; evidence supports HAC |
| Whether peremptory challenges to exclude jurors with death‑penalty reservations violated constitutional rights | Lucas | Bowles and Knowles standards apply | Not contrary to or an unreasonable application of Supreme Court law |
Key Cases Cited
- Baldwin v. Reese, 541 U.S. 27 (2004) (fair presentation requires federal framing or notice)
- Bowles v. Sec’y, Dep’t of Corr., 608 F.3d 1313 (11th Cir. 2010) (no clearly established death‑penalty peremptory‑challenge rule)
- Knowles v. Mirzayance, 556 U.S. 111 (2009) (no clearly established law prohibiting state use of peremptory challenges to death‑penalty opponents)
- Davis v. Alaska, 415 U.S. 308 (1974) (confrontation rights for witnesses)
- Wardius v. Oregon, 412 U.S. 470 (1973) (discovery disclosures and fairness)