Reynolds v. State, 99 So. 3d 459

Reynolds was convicted of first-degree murder (Razors), second-degree murder (Privett), and burglary with a resulting battery; death sentences for the Razor murders and life for Privett; all sentences run concurrently.
This Court affirmed on direct appeal; US Supreme Court denied certiorari in 2007.
Postconviction, Reynolds sought relief under Rule 3.851 asserting numerous claims including DNA/Badger testimony issues, Brady/VN claims, ineffective assistance of counsel, and mitigation/waiver arguments.
The postconviction court held a Huff hearing, denied some claims summarily, and granted an evidentiary hearing on others; after hearings, it denied all claims, and Reynolds appealed.
Key contested issues include: Badger DNA testimony transcript discrepancy, burden-of-proof misstatements in voir dire, lay witness testimony about hand injury and clothing, a sleeping juror, memorial/shrine outside the courtroom, and mitigation/evidence strategies.
The Florida Supreme Court reviews de novo the legal conclusions and applies Strickland standards to ineffective-assistance claims, deferring to the postconviction court on factual findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ineffective assistance for Badger testimony	Reynolds claims trial/counsel failed to object to false DNA testimony by Badger.	Counsel's performance was not deficient; transcript error was clerical and harmless.	Denied; no deficient performance or prejudice.
Burden-of-proof misstatement during voir dire	Trial court misstated burden of proof; error not cured and prejudicial.	Misstatement was isolated, curable, and not prejudicial; bar applies.	Procedurally barred and meritless; no reversible error.
Lay witness testimony re hand injury	Defense was ineffective for permitting lay专家 opinion on metallurgy/oxidation.	Testimony fell within lay observation; if expert, prejudice issue lacking.	Denied; testimony within lay range and not prejudicial.
Sleeping juror	Defense should have moved to remove sleeping juror.	Issue was addressed at trial; strategic reasons support not removing.	Denied; transcript shows trial addressed the issue and no reversible prejudice.
Mitigation waiver and failure to present mitigation	Counsel failed to investigate/present substantial mitigation; waiver not knowing/voluntary.	Reynolds knowingly, voluntarily waived mitigation after thorough court inquiry; evidence shows strategic choice.	Denied; waiver valid and mitigation presentation would have been cumulative.

Strickland v. Washington, 466 U.S. 668 (U.S. Supreme Court 1984) (establishes two-prong standard for ineffective assistance)
Gonzalez v. State, 990 So.2d 1017 (Fla. 2008) (waiver of right to testify evaluated under knowing/voluntary standard)
Murray v. State, 937 So.2d 277 (Fla. 4th DCA 2006) (fundamental error standard for erroneous burden-of-proof instruction; comparison to harmless error)
Simo v. State, 790 So.2d 1190 (Fla. 4th DCA 2001) (waiver/ineffective assistance considerations for sleeping juror)
Terrell v. State, 9 So.3d 1284 (Fla. 4th DCA 2009) (reversal/remand for sleeping juror claims when trial addressed the issue)