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124 So. 3d 811
Fla.
2013
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Background

  • February 20, 2008: police respond to a man in distress; find Kirk Zoeller outside an apartment, stabbed to death, and Donna Trujillo dead in the bedroom; both pronounced dead; crime scene shows extensive stabbing.
  • Theresa Teague allowed police to search her home; Matthews is found hiding under clothes, shirt, and knife-related evidence discovered; a search warrant yields Zoeller’s wallet and a bloody shirt in Teague’s home.
  • Matthews made statements to detectives outside Teague’s house and later, after being informed Zoeller was dead, claimed self-defense and that Zoeller killed Trujillo.
  • Wagner testified Matthews chased and stabbed Zoeller in the bedroom with a big knife; Teague testified to Matthews’ incriminating statements and that Matthews previously received a knife.
  • DNA testing linked Matthews to the bloody shirt and sneakers and Zoeller’s blood on multiple items; a traffic citation with Matthews’ name was found in the jeans’ pocket; Zoeller’s wallet was found with Matthews’ bloody shirt.
  • Jury convicted Matthews of first-degree premeditated and felony murder of Zoeller, and of Manslaughter of Trujillo; burglary while armed; during penalty phase, multiple mitigating and aggravating factors were presented; Matthews was sentenced to death, with additional sentences for burglary and manslaughter to be served consecutively.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Constitutional viability of Ring-based death-penalty claims Matthews argues Ring-based limits apply to death-qualification. Court need not address Ring claims because burglary aggravator exists. Ring claims not reached; aggravators predominate; Ring not applicable here.
Constitutionality of HAC and in-the-course-of-a-felony aggravators and related jury instructions HAC and course-of-a-felony aggravators are unconstitutional as vague/overbroad. This Court has repeatedly upheld them. Aggravators and instructions upheld as constitutional.
Sufficiency of the evidence to sustain first-degree murder conviction Evidence not enough to prove premeditation and felony murder. Evidence shown by Wagner, DNA, and scene supports conviction. Competent, substantial evidence supports premeditated murder and felony-murder finding.
Proportionality of the death sentence Death penalty not proportional to the offense. Court should compare to other cases upholding death sentences. Sentence proportional given aggravators and mitigators.

Key Cases Cited

  • Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (death penalty not automatic without juror finding of aggravating factors)
  • Baker v. State, 71 So.3d 802 (Fla.2011) (Ring not implicated when burglary aggravator established)
  • Hodges v. State, 55 So.3d 515 (Fla.2010) (Ring not applicable when under-sentence or prior violent felony aggravators present)
  • Ault v. State, 866 So.2d 674 (Fla.2008) (upholds HAC aggravator constitutionality)
  • Francis v. State, 808 So.2d 110 (Fla.2001) (upholds HAC aggravator instruction)
  • Blanco v. State, 706 So.2d 7 (Fla.1997) (HAC advisory clarity in aggravating instruction)
  • Merck v. State, 664 So.2d 989 (Fla.1995) (HAC instruction not unconstitutionally vague or overbroad)
  • Pham v. State, 70 So.3d 485 (Fla.2011) (proportionality framework for death sentences)
  • England v. State, 940 So.2d 389 (Fla.2006) (proportionality review standards and mitigating factors)
  • Davis v. State, 2 So.3d 952 (Fla.2008) (death-penalty sufficiency in stabbing murders under totality of evidence)
  • Walker v. State, 957 So.2d 560 (Fla.2007) (death sentence proportionality in aggravated murders)
  • Duest v. State, 855 So.2d 33 (Fla.2003) (death sentence proportionality with multiple mitigators)
  • Singleton v. State, 783 So.2d 970 (Fla.2001) (death sentence proportionality in stabbing murder)
  • Johnson v. State, 660 So.2d 637 (Fla.1995) (death penalty proportionality in stabbing murder)
  • Spencer v. State, 615 So.2d 688 (Fla.1993) (standard for Spencer hearing)
Read the full case

Case Details

Case Name: Matthews v. State
Court Name: Supreme Court of Florida
Date Published: Feb 21, 2013
Citations: 124 So. 3d 811; 38 Fla. L. Weekly Supp. 134; 2013 WL 627131; 2013 Fla. LEXIS 270; No. SC10-1771
Docket Number: No. SC10-1771
Court Abbreviation: Fla.
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