Ray Jackson v. State of Florida
147 So. 3d 469
| Fla. | 2014Background
- Florida Supreme Court affirms denial of postconviction relief and DNA testing in Jackson v. State, capital defendant who was sentenced to death for kidnapping and first-degree murder.
- Jackson and codefendant Wooten were tried together; Jackson convicted and sentenced to death; direct appeal affirmed.
- Postconviction motions under Fla. R. Crim. P. 3.851 and 3.853 were litigated; evidentiary hearing held on some claims; DNA testing denied.
- The court applied Strickland v. Washington standards to assess ineffective assistance of counsel claims and reviewed the denial of relief de novo for legal conclusions while deferring to trial court findings of fact.
- The opinion ultimately rejects all relief requests and affirms the postconviction court’s rulings, including denial of DNA testing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance—general standard and cumulative errors | Jackson asserts cumulative errors entitlement. | State contends no single error proven; cumulative errors fail. | Denied; no prejudice shown for cumulative errors. |
| Failure to investigate Curtis Lewis’s testimony | Keating failed to personally investigate Lewis; testimony would show alive after 11/9/2004. | Counsel relied on investigator; no deficiency; evidence supported trial date. | Denied; no deficient performance or prejudice. |
| Use of serial killer defense and lack of crime‑scene experts | Keating ineffective for pursuing serial killer theory and not hiring experts. | Strategy reasonable; experts unnecessary given circumstances. | Denied; not deficient under Strickland. |
| Failure to uncover MBI/online articles and motive against Cleo’s | Counsel should have discovered articles and pursued alternative theory. | Investigation timing and distance rendered theory unlikely; not deficient. | Denied; lack of prejudice. |
| DNA testing—postconviction hairs at gravesite | Rule 3.853 requires relief if DNA testing could exonerate or mitigate. | Hair evidence unlikely to prove innocence or mitigation; fishing expedition. | Denied; no reasonable probability of exoneration or mitigation. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong test for ineffective assistance of counsel)
- Occhicone v. State, 768 So.2d 1037 (Fla. 2000) (strong presumption against ineffective assistance; strategic decisions favored)
- McCoy v. State, 113 So.3d 701 (Fla. 2013) (cumulative standard for considering claims of ineffective assistance)
- Wade v. State, 41 So.3d 857 (Fla. 2010) (limits on improper vouching or bolstering by state witnesses)
- Williamson v. State, 994 So.2d 1000 (Fla. 2008) (guidance on prosecutorial rebuttal and defense credibility)
- Braddy v. State, 111 So.3d 810 (Fla. 2012) (prosecutor comments and fair rebuttal considerations)
- Lott v. State, 931 So.2d 807 (Fla. 2006) (DNA testing standards under Fla. R. Crim. P. 3.853)
- Huff v. State, 495 So.2d 145 (Fla. 1986) (standard governing postconviction DNA testing requests)