Michael T. Rivera v. State of Florida, 260 So. 3d 920

Michael T. Rivera was convicted of first-degree murder (abduction and killing of 11‑year‑old Staci Jazvac) and sentenced to death; his conviction became final in 1990.
At trial the State relied on confessions to multiple people (including a victim of obscene phone calls, Starr Peck) and jailhouse informants; the jury recommended death unanimously.
Rivera pursued multiple rounds of postconviction relief (3.850/3.851); prior appeals (Rivera I–V) rejected guilt-phase and many penalty-phase claims, including a newly discovered DNA/hair-evidence claim.
After Hurst v. State and related developments, Rivera filed a second successive 3.851 motion asserting entitlement to Hurst relief, sought permission to exceed a 25‑page limit, and requested a Huff case‑management hearing.
The postconviction court denied the successive motion (and the page‑limit enlargement); Rivera appealed and the Florida Supreme Court affirmed, finding his claims meritless or procedurally barred.

Issue	Plaintiff's Argument (Rivera)	Defendant's Argument (State)	Held
1) Denial of motion to exceed 25‑page limit	Rule 3.851 page limit deprived Rivera of equal protection and prevented full presentation of complex Hurst claim	Court discretion valid; Hurst relief inapplicable here, so enlargement not warranted	Denial was not an abuse of discretion and was proper
2) Failure to hold Huff case‑management hearing	Absence of Huff hearing denied due process	Successive motions need not receive Huff if legally insufficient; any error harmless because motion lacked merit	Failure to hold Huff hearing was harmless error
3) Retroactivity: Hurst should apply because aggravator findings are substantive	Hurst (and related doctrines) alter substantive punishment elements and should be applied retroactively	Florida precedent forecloses retroactive Hurst for cases final before Ring; Hurst penalty findings are not elements of murder	Argument rejected—Hurst not retroactive to Rivera (final pre‑Ring)
4) Newly discovered DNA/hair evidence and Eighth Amendment reliability	New testing undermines jury evidence; sentence unreliable under Eighth Amendment	DNA/hair results are cumulative or non‑exculpatory given strong confession and other evidence; claim previously litigated and is procedurally barred	Claim procedurally barred and merits denied; new evidence would not probably produce acquittal or lesser result

Rivera v. State, 561 So. 2d 536 (Fla. 1990) (direct‑appeal decision summarizing facts and convictions)
Rivera v. State, 187 So. 3d 822 (Fla. 2015) (prior postconviction decision rejecting newly discovered DNA/hair‑evidence claim)
Hurst v. State, 202 So. 3d 40 (Fla. 2016) (announcing Hurst‑related jury findings required for death penalty)
Ring v. Arizona, 536 U.S. 584 (2002) (jury must find aggravating facts necessary to impose death)
Asay v. State, 210 So. 3d 1 (Fla. 2016) (Hurst not applied retroactively to cases final before Ring)
Groover v. State, 703 So. 2d 1035 (Fla. 1997) (Huff hearing requirement limited to initial postconviction motions)