778 F.3d 1234
11th Cir.2015Background
- Antonio Melton was convicted in Florida of armed robbery and first‑degree felony murder; jury recommended death and judge imposed death.
- Melton was 18 years, 25 days old at the Carter murder; the trial court relied on a prior first‑degree felony murder conviction committed when Melton was 17 as a significant aggravating factor.
- Melton sought state postconviction relief; the Florida Supreme Court denied relief and affirmed the death sentence.
- Melton filed a federal §2254 habeas petition arguing, under Roper v. Simmons, that (1) his juvenile prior conviction could not be used as an aggravator and (2) his lesser "mental and emotional age" should bar death; the district court denied relief and a certificate of appealability (COA).
- Melton moved this Court to amend his COA application to add the two Roper‑based issues; the majority denied the motion and refused a COA, while Judge Martin dissented and would have granted a limited COA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Roper prohibits using a conviction committed while a defendant was a juvenile as an aggravating factor in a later capital sentencing | Melton: a juvenile conviction used as the weightiest aggravator makes imposition of death unconstitutional under Roper | State/majority: Roper bars execution of those who committed capital crimes under 18, but does not address use of prior juvenile convictions as aggravators; no Supreme Court precedent forbids it | Denied COA — not debatable that Florida Supreme Court did not unreasonably apply clearly established federal law |
| Whether a defendant’s "mental and emotional age" (below 18) bars imposition of death though chronologically over 18 | Melton: despite being 18, his mental/emotional immaturity made him comparable to juveniles protected by Roper | State/majority: Roper adopted a categorical 18‑year cutoff; Supreme Court has not required individualized mental‑age exceptions and dicta supports drawing the line at 18 | Denied COA — not debatable that state court’s decision was consistent with clearly established Supreme Court precedent |
Key Cases Cited
- Roper v. Simmons, 543 U.S. 551 (2005) (bars execution of offenders who committed capital crimes under 18; discusses categorical cutoff and youth characteristics)
- Atkins v. Virginia, 536 U.S. 304 (2002) (Eighth Amendment bars execution of intellectually disabled offenders; reasoning influential to Roper)
- Harrington v. Richter, 562 U.S. 86 (2011) (AEDPA deference: state decision is unreasonable only if no fairminded jurists could agree with it)
- Miller‑El v. Cockrell, 537 U.S. 322 (2003) (standard for granting a certificate of appealability requires more than absence of frivolity)
- Slack v. McDaniel, 529 U.S. 473 (2000) (COA requires showing that reasonable jurists could debate the district court’s resolution)
- Panetti v. Quarterman, 551 U.S. 930 (2007) (AEDPA does not bar applying principles to different facts; courts can find state application unreasonable on novel fact patterns)
- Harmelin v. Michigan, 501 U.S. 957 (1991) (Eighth Amendment in capital context receives special force; "death is different")
- Wong v. Belmontes, 558 U.S. 15 (2009) (recognizes prior murder participation as especially weighty aggravating evidence)
- Enmund v. Florida, 458 U.S. 782 (1982) (limits death penalty for certain classes of offenders)
- Coker v. Georgia, 433 U.S. 584 (1977) (Eighth Amendment prohibits death penalty for some serious crimes)