Lucious Boyd v. State of Florida, 324 So.3d 908

Lucious Boyd was convicted in 1998 of first-degree murder, armed kidnapping, and sexual battery, and sentenced to death; his convictions and sentences were previously affirmed on direct appeal and in multiple postconviction/habeas proceedings.
Boyd filed a second successive 3.851 motion alleging juror misconduct by juror Tonja Striggles based on testimony given at a federal evidentiary hearing.
At the federal hearing Striggles disclosed she learned during a voir dire break (by calling her mother) that a cousin was married to Boyd’s brother, that the victim’s body had been found near her home and was discussed by family/neighbors, and that medication made her lethargic during trial.
The postconviction court summarily denied Boyd’s motion without a Huff (case-management) hearing or an evidentiary hearing and provided no explanation; Boyd appealed.
The Florida Supreme Court applied the Martin two-prong standard for juror-misconduct claims (dishonest answer to material voir dire question + actual bias) and concluded Boyd’s motion was legally insufficient; it affirmed the summary denial. Justice Labarga dissented, arguing the federal hearing revealed inconsistencies warranting an evidentiary hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to hold a Huff hearing required reversal	Boyd: court should have held Huff before summary denial; lack of explanation compounded error	State: Huff applies to initial, not successive motions; any error harmless if motion legally insufficient	Court: No reversible error; Huff requirement is for initial motions and any failure is harmless where the motion is legally insufficient
Whether summary denial without evidentiary hearing was proper on juror-misconduct claim	Boyd: federal hearing revealed Striggles omitted material voir dire information (familial tie, pretrial knowledge, medication) warranting an evidentiary hearing or new trial	State: Claim procedurally barred in part; even on merits the record does not show dishonesty or actual bias sufficient to require a hearing	Court: Denial affirmed — Boyd failed to show (1) dishonest answer to a material voir dire question and (2) actual bias under Martin; summary denial appropriate

Huff v. State, 622 So. 2d 982 (Fla. 1993) (Huff hearing requirement for initial capital postconviction motions)
Boyd v. State, 910 So. 2d 167 (Fla. 2005) (direct appeal affirming convictions and sentencing)
Boyd v. State, 200 So. 3d 685 (Fla. 2015) (discussing juror-misconduct and actual-bias principles)
Boyd v. State, 291 So. 3d 900 (Fla. 2020) (affirming denial of first successive postconviction motion)
Tompkins v. State, 994 So. 2d 1072 (Fla. 2008) (standard for summary denial of postconviction motions)
McDonough Power Equip., Inc. v. Greenwood, 464 U.S. 548 (1984) (venire dishonesty materiality standard)
Carratelli v. State, 961 So. 2d 312 (Fla. 2007) (definition of actual bias)
Hendrix v. State, 136 So. 3d 1122 (Fla. 2014) (successive motions may not relitigate previously rejected claims)
Marshall v. State, 854 So. 2d 1235 (Fla. 2003) (Florida rule limiting juror testimony about matters inhering in verdict)
Tanner v. United States, 483 U.S. 107 (1987) (limits on juror testimony about extraneous influences)
Neder v. United States, 527 U.S. 1 (1999) (materiality standard for omitted information)
Devoney v. State, 717 So. 2d 501 (Fla. 1998) (prohibition on inquiry into jurors' subjective mental processes)
Irwin v. Dowd, 366 U.S. 723 (1961) (preconceived notions do not automatically disqualify a juror)
Groover v. State, 703 So. 2d 1035 (Fla. 1997) (Huff practice and court discretion)
Taylor v. State, 260 So. 3d 151 (Fla. 2018) (Huff error harmless if motion legally insufficient)