Patrick v. State
104 So. 3d 1046
| Fla. | 2012Background
- Patrick beat Schumacher to death, bound and gagged him, and left him in the bathtub after stealing Schumacher’s truck and wallet.
- He fled with Schumacher’s money, ATM card, and other items; approximately $900 was withdrawn from Schumacher’s account.
- Patrick was arrested on an outstanding warrant after an unrelated encounter with a deputy; DNA linked Schumacher’s blood to Patrick’s jeans.
- Trial in 2009 resulted in guilty verdicts for first‑degree murder, kidnapping, and robbery; death sentence imposed in 2009 with multiple aggravators and mitigating factors.
- Penalty phase included Spencer considerations; court found six aggravators (three weighty) and various mitigating factors, sentencing Patrick to death; CCP aggravator later struck on appeal.
- Court affirmed Patrick’s conviction and death sentence despite some reversed aggravator and challenged claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Juror disqualification during voir dire | Patrick claims improper early strikes for hardship | State argues discretion to strike hardship jurors | Court upheld the hardship-based excusal as discretionary |
| Limitation of cross-examination (Diez and related witnesses) | Patrick asserts limited cross-exam prevented credibility challenges | Court properly limited non-relevant or unreliable inquiry | Court held no abuse; cross was within discretion and sufficient impeachment existed |
| Voluntary intoxication instruction | Instruction impermissibly commented on evidence | Instruction reflects current law eliminating voluntary intoxication defense | Instruction was proper as a correct statement of law |
| Motion to suppress confession and bag search | Confession and evidence fruit of unlawful detention | Encounter progressed from consensual to arrest; suppression denied | Ruling upheld; encounter lawfully progressed to arrest under warrant |
| Admission of autopsy photographs | Photographs were gruesome and prejudicial | Photographs assisted testimony and were relevant | Photographs admissible; not unduly prejudicial |
Key Cases Cited
- Sanders v. State, 707 So.2d 664 (Fla.1998) (death-penalty voir dire; require opportunity to rehabilitate jurors expressing death-penalty scruples)
- Taylor v. State, 855 So.2d 1 (Fla.2003) (consensual encounter framework for suppression analysis)
- McDuffie v. State, 970 So.2d 312 (Fla.2007) (cross-examination breadth and Sixth Amendment confrontation rights)
- Coco v. State, 62 So.2d 892 (Fla.1953) (cross-examination scope extends to subject matter opened on direct)
- Davis v. Alaska, 415 U.S. 308 (U.S. 1974) (Sixth Amendment right to confront witnesses; cross-examination core purpose)
- Gibbs v. State, 904 So.2d 432 (Fla.2005) (voluntary intoxication instruction proper following statutory change)