Reynaldo Figueroa-Sanabria v. State of Florida, 366 So.3d 1035

On April 12, 2013, John Travlos and Germana Morin were fatally stabbed on their houseboat; jewelry worth over $80,000 was taken and there was no sign of forced entry.
Reynaldo Figueroa-Sanabria, the victims’ handyman, was seen near the boat the night before; DNA matching him was found on a roll and wad of duct tape at the scene and victims’ DNA was found on clothes later recovered in a dumpster.
Cooper (his girlfriend) drove him the morning after the murders; he sold some of the jewelry, shipped more to his brother, and then fled before being arrested in North Carolina.
Hammond served as lead defense counsel amid a contentious attorney–client relationship and multiple requests by Figueroa-Sanabria to replace him; co-counsel Hernandez was designated to handle the penalty phase.
At trial the State introduced historical cell-site location information (CSLI) obtained earlier without a warrant; Figueroa-Sanabria was convicted of two counts of first-degree murder and sentenced to death after a penalty phase in which he initially waived counsel (then partially reinstated counsel during deliberations).

Issue	Figueroa‑Sanabria’s Argument	State’s Argument	Held
Trial court refusal to replace court‑appointed counsel before guilt phase	Relationship with Hammond had collapsed; replacement required	Court‑appointed counsel was providing adequate assistance; indigent defendant has no right to chosen appointed lawyer	No abuse of discretion; denial of substitution affirmed and guilt‑phase stands
Admissibility of historical CSLI obtained without a warrant	CSLI acquisition violated Fourth Amendment per Carpenter; evidence should be suppressed	CSLI was acquired consistent with binding precedent at the time; if error occurred it was harmless	Even if admission erroneous, error harmless beyond reasonable doubt; convictions affirmed
Sufficiency of the evidence for first‑degree murder	(General challenge) evidence insufficient	State had strong physical, forensic, and circumstantial evidence tying defendant to murders	Independent review finds substantial, competent evidence supports convictions
Waiver of counsel for penalty phase / forced choice	Trial court conditioned appointed counsel’s assistance on counsel presenting mitigation, coercing waiver to proceed pro se	Court complied with Faretta colloquy; defendant chose to waive	Waiver not knowing/intelligent because court misinformed defendant; deprivation of counsel during most of penalty phase is fundamental error — death sentences vacated and new penalty phase ordered

Faretta v. California, 422 U.S. 806 (1975) (defendant has constitutional right to proceed pro se; waiver must be knowing, intelligent, and voluntary)
Carpenter v. United States, 138 S. Ct. 2206 (2018) (Supreme Court rule that warrant is required for access to historical CSLI)
Davis v. United States, 564 U.S. 229 (2011) (good‑faith exception: reliance on binding precedent can render exclusionary rule inapplicable)
Gideon v. Wainwright, 372 U.S. 335 (1963) (right to appointed counsel in state criminal prosecutions)
DiGuilio v. State, 491 So. 2d 1129 (Fla. 1986) (harmless‑error standard and framework for evaluating whether an error contributed to a verdict)
United States v. Cronic, 466 U.S. 648 (1984) (structural error doctrine where adversarial testing is deprived by counsel’s absence)
Traylor v. State, 596 So. 2d 957 (Fla. 1992) (waiver of counsel principles and presumption against waiver of important rights)
Jackson v. State, 983 So. 2d 562 (Fla. 2008) (examples and treatment of deprivations of counsel as fundamental error)