124 So. 3d 811
Fla.2013Background
- 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)
