Richard E. Lynch v. Secretary, Florida Department of Corrections
2015 U.S. App. LEXIS 307
| 11th Cir. | 2015Background
- Lynch murdered Morgan and her daughter Caday in 1999; trial evidence was overwhelming and included a confession and witnesses.
- Lynch pleaded guilty to all four counts in 2000 after his experienced capital-trial lawyers advised waiving a sentence-stage jury.
- Mitigation at sentencing relied on a neuropsychologist and other experts; the court found multiple aggravators and eight non-statutory mitigators.
- Lynch’s direct appeal upheld convictions; post-conviction relief was sought, including new brain-impairment evidence and ineffective-assistance claims.
- The district court granted habeas relief on the sentence-stage jury-waiver claim but denied the other three claims; the Eleventh Circuit reviews under AEDPA.
- The court considers three cross-appeal claims (guilty-plea advice, suppression of the murder-suicide letter, and brain-impairment mitigation) before addressing the direct-appeal challenge.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Guilty-plea advice prejudice | Lynch argues counsel's advice was ineffective and prejudicial under Hill v. Lockhart. | Florida Supreme Court held no prejudice; defenses were unlikely and recommending mitigation was reasonable strategy. | No prejudice under Hill; claim fails. |
| Suppression of murder-suicide letter | Counsel failed to move to suppress the letter under Fourth Amendment grounds, undermining mitigation. | State court found consent and plain-view seizure lawful; decision reasonable under AEDPA. | No merit; suppression issue resolved against Lynch. |
| Brain-impairment mitigation evidence | Counsel's failure to obtain/present brain-impairment evidence prejudiced sentencing. | Florida Supreme Court reasonably weighed the evidence and found no prejudice; new evidence would not alter the balance of aggravators and mitigators. | No prejudice; AEDPA deferential deference to Florida Supreme Court; claim fails. |
Key Cases Cited
- Hill v. Lockhart, 474 U.S. 52 (Sup. Ct. 1985) (prejudice inquiry for guilty-plea advice; effect on trial decision matters)
- Strickland v. Washington, 466 U.S. 668 (Sup. Ct. 1984) (standard for ineffective assistance of counsel)
- Kimmelman v. Morrison, 477 U.S. 365 (Sup. Ct. 1986) (Fourth Amendment ineffective assistance carve-out in habeas cases)
- Hoskins v. State, 965 So. 2d 1 (Fla. 2007) (planning element and lack of extreme mental or emotional disturbance evidence)
- Rutherford v. Crosby, 385 F.3d 1300 (11th Cir. 2004) (prejudice under brain-impairment mitigation in death-penalty sentencing)
- Pilla v. United States, 668 F.3d 368 (6th Cir. 2012) (objective prejudice assessment in Hill framework)
- Evans v. Sec’y, Fla. Dep’t of Corr., 703 F.3d 1316 (11th Cir. 2013) (AEDPA deference and state-court prejudice determinations)