Michael Gordon Reynolds v. State of Florida, 373 So.3d 1124

Reynolds was convicted in 2003 of three murders; trial evidence included his blood and hair inside the victims’ trailer, eyewitnesss, admissions to inmates, a neighbor’s observation of his car at the victims’ residence, and evidence he bleached clothes after the murders.
On direct appeal the convictions and death sentences were affirmed; Reynolds subsequently pursued postconviction relief, including a 2013 Rule 3.853 motion seeking DNA testing of 24 items, which the trial court denied and this Court affirmed (Reynolds II).
Reynolds filed a successive Rule 3.853 motion seeking DNA testing of many of the same items previously litigated and several additional items and testing methods; the trial court summarily denied the motion as procedurally barred and insufficiently pled.
The Supreme Court reviewed the appeal de novo and addressed both procedural-bar grounds (res judicata/collateral estoppel) and the substantive Rule 3.853 standard requiring a reasonable probability of acquittal or a lesser sentence.
The Court held the successive motion was procedurally barred (claims already raised or could have been raised earlier) and, alternatively, failed on the merits because additional DNA testing would not create the required reasonable probability of acquittal or reduction in sentence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural bar / relitigation of previously rejected claims	Reynolds: motion allowed despite prior denial; seeks testing of items (some previously litigated)	State: claims already raised and rejected; barred by collateral estoppel/res judicata	Held: Procedurally barred; prior denial (Reynolds II) prevents relitigation
Requests for items known at trial but not previously tested	Reynolds: newly requested items warrant testing now	State: items were known at trial and could have been raised earlier; barred by res judicata	Held: Barred — could have been raised earlier; not allowed in successive motion
Rule 3.853 nexus / reasonable probability of acquittal	Reynolds: additional DNA testing could exonerate him or undermine State’s case	State: conviction supported by non-DNA evidence (confessions, eyewitnesses, bleaching, prior DNA) so testing would not create reasonable probability of acquittal	Held: Merits fail — no reasonable probability testing would lead to acquittal
Reduced-sentence claim via relative culpability	Reynolds: testing could show another’s involvement and reduce death sentence to life	State: relative culpability doctrine no longer supports such relief; claim speculative	Held: Fails — Court abandoned relative culpability doctrine; claim speculative and insufficient

Reynolds v. State, 934 So. 2d 1128 (Fla. 2006) (direct-appeal opinion describing trial evidence supporting convictions)
Reynolds v. State, 192 So. 3d 41 (Fla. 2015) (table decision affirming denial of 2013 DNA-testing motion)
Hendrix v. State, 136 So. 3d 1122 (Fla. 2014) (claims rejected in prior postconviction proceedings are procedurally barred)
Van Poyck v. State, 116 So. 3d 347 (Fla. 2013) (procedural bar principles for successive motions)
Barwick v. State, 361 So. 3d 785 (Fla. 2023) (claims that could have been raised previously are barred)
State v. McBride, 848 So. 2d 287 (Fla. 2003) (collateral estoppel in postconviction context)
Hitchcock v. State, 866 So. 2d 23 (Fla. 2004) (Rule 3.853 requires nexus showing and reasonable probability of acquittal or lesser sentence)
Rogers v. State, 327 So. 3d 784 (Fla. 2021) (standard of review — de novo)
Spencer v. State, 615 So. 2d 688 (Fla. 1993) (procedure for sentencing-phase presentation of mitigation)
Tanzi v. State, 94 So. 3d 482 (Fla. 2012) (res judicata bars claims raiseable earlier)
Topps v. State, 865 So. 2d 1253 (Fla. 2004) (res judicata in postconviction proceedings)