Peterson v. State
94 So. 3d 514
| Fla. | 2012Background
- Peterson was convicted of first-degree murder and tampering with evidence for the August 8, 2005 killing of his 64-year-old stepfather, Roy Andrews.
- The State presented premeditation and planning evidence, including admissions and a videotaped confession to a friend who was an undercover police informant.
- Andrews was a counselor who arrived early at a treatment center; Peterson’s motive centered on money and independence from Andrews’ control.
- Peterson’s defense portrayed him as having cocaine addiction issues but not as actively using drugs, while the State emphasized his premeditated scheme and disposal of evidence.
- The penalty phase yielded a seven-to-five jury recommendation of death based on CCP, HAC, and pecuniary gain, with nonstatutory mitigators given lesser weight.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of evidence implying prior murder | Peterson’s ‘stacked em double’ remark implied a prior murder. | This statement was prejudicial and minimally probative, should have been redacted. | No fundamental error; statement not required to be redacted and not automatically prejudicial. |
| Suppression of statements to Jackson | Peterson coerced, Miranda warnings not given; custodial interrogation occurred. | The interrogation was noncustodial and voluntary; Miranda not required. | Court affirmed denial of suppression; interrogation not custodial under Standard. safeguards applied. |
| Cold, calculated, and premeditated (CCP) aggravator | Peterson’s cocaine addiction undermines CCP finding as undermining deliberation. | Deliberate planning and premeditation shown despite addiction. | CCP affirmed; evidence showed careful planning and premeditation. |
| Murder for pecuniary gain | Motive shown by financial support patterns and expenditures. | Evidence insufficient or improperly weighed; mitigates weight. | Affirmed as supported by competent substantial evidence; pecuniary gain upheld. |
| Victim impact evidence in penalty phase | Victim’s life and service background are proper impact evidence. | Closing argument impermissibly contrasted victim with defendant. | Not reversible error; evidence within statutory boundary and curative instruction given. |
Key Cases Cited
- England v. State, 940 So.2d 389 (Fla. 2006) (fundamental error standard for impact of collateral crime statements; fleeting admission not reversible error)
- Ramirez v. State, 739 So.2d 568 (Fla. 1999) (custodial interrogation framework; Miranda applicability standard)
- Yarborough v. Alvarado, 541 U.S. 652 (U.S. 2004) (two-step custody analysis for Miranda applicability; reasonable-person standard)
- Bell v. State, 841 So.2d 329 (Fla. 2002) (weight given mitigating factors; age-specific considerations)
- Turner v. State, 37 So.3d 212 (Fla.) (analogous consideration of cocaine influence on CCP determination; capacity concerns addressed)