McCray v. State, 71 So. 3d 848

Background

McCRAY was convicted of four counts of first‑degree murder for a May 23, 2004 shooting spree at a drug house in Orange Park; DNA on a sweatshirt at the scene linked him to the crime; the weapons were not recovered; he was found competent to stand trial after multiple competency proceedings; the penalty phase resulted in four death sentences after a Spencer hearing and victim‑impact evidence; on direct appeal he raises eleven claims challenging competency, Faretta self‑representation, evidentiary rulings, and the sufficiency and proportionality of the death sentences.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the trial court err in finding McCRAY competent to proceed after the final competency hearing?	McCRAY contends competency was not shown due to conflicting expert opinions.	State argues the court properly weighed expert testimony and resolved conflicts.	No abuse of discretion; competent, substantial evidence supported the trial court’s competency ruling.
Was the Faretta self‑representation inquiry properly conducted for each challenged stage?	McCRAY asserts multiple failures to conduct Faretta inquiries after self‑representation requests.	State contends many requests were equivocal or did not trigger a Faretta hearing; some inquiries were sufficient.	Mostly denied; some claims rejected as non‑unequivocal or non‑triggering; others found non‑abusive where applicable.
Did the trial court properly limit McCRAY’s narrative guilt‑phase testimony without violating the right to testify?	McCRAY argues unilateral narrative testimony violated his right to present evidence.	State contends trial court properly curtailed non‑responsive, irrelevant, or prejudicial testimony.	No abuse; court acted within discretion to limit testimonial narrative and preserve trial integrity.
Did admission of collateral drug‑related evidence violate Williams or prejudice the trial?	Williams rule precludes collateral acts unless probative value substantially outweighs prejudice.	Collateral acts were relevant to motive and did not become a trial feature.	No reversible error; collateral evidence admitted for motive and did not overwhelmingly prejudice the trial.
Is the penalty phase jury instruction or Muhammad v. State limitation error warranted?	McCRAY argues the jury instruction and Muhammad safeguards were violated or misapplied.	Court properly applied standard instructions; Muhammad safeguards inapplicable where mitigation was not completely waived.	No error; instructions were proper and Muhammad safeguards did not apply given the mitigation strategy.

Key Cases Cited

Potts v. State, 718 So.2d 757 (Fla. 1998) (Faretta inquiry focuses on defendant’s understanding of rights; not exact colloquy words)
Faretta v. California, 422 U.S. 806 (U.S. 1975) (Right to self‑representation requires knowing, voluntary waiver; no magic words required)
Edwards v. Arizona, 554 U.S. 164 (U.S. 2008) (Sixth Amendment right to self‑representation; states may balance rights when mental competency is involved)
Mora v. State, 814 So.2d 322 (Fla. 2002) (Trial court’s handling of closing argument follows discretion; competency history considered)
Mason v. State, 597 So.2d 776 (Fla. 1992) (Trial court’s weighing of conflicting expert testimony is bound by competent, substantial evidence)