Richard E. Lynch v. State of Florida, 254 So. 3d 312

Richard E. Lynch pled guilty to two counts of first-degree murder (victims: Roseanna Morgan and her 13-year-old daughter Leah Caday), kidnapping, and armed burglary for killings on March 5, 1999; he received two death sentences after a bench penalty-phase (he waived a jury).
Facts: Lynch stalked Morgan after an affair ended, brought multiple guns to her apartment, held Caday hostage, shot Morgan multiple times (including an execution-style shot) and shot Caday; he called 911 and confessed; police negotiated and he surrendered.
At sentencing the trial court found multiple aggravators (including CCP and HAC) and several mitigators (mental illness, impaired capacity, lack of significant prior criminal history, cooperation, remorse); the court weighed aggravators more heavily and imposed death.
Lynch pursued direct appeals and multiple rounds of postconviction and federal habeas litigation; his convictions and sentences were repeatedly affirmed or partially addressed on habeas; his sentences became final in 2003.
Lynch filed a successive 3.851 motion seeking Hurst-based relief, arguing (1) his waiver of a penalty-phase jury was invalid because counsel’s deficient mitigation investigation led to an uninformed waiver, and (2) the Strickland prejudice analysis should be altered post-Hurst; the trial court denied relief and this appeal followed.

Issue	Plaintiff's Argument (Lynch)	Defendant's Argument (State)	Held
Validity of Lynch’s waiver of penalty-phase jury	Waiver was unknowing/invalid because counsel failed to investigate mild cognitive impairment and thus gave deficient advice before Lynch waived jury sentencing	Lynch executed a thorough oral and written waiver; waiver was knowing and voluntary; Mullens bars Hurst relief where waiver was valid	Waiver was valid and knowing; Mullens controls — no Hurst relief for waiver-based claim
Whether Strickland prejudice standard changed after Hurst	Post-Hurst, prejudice analysis should be reconsidered and may now show counsel’s failure to investigate mitigation was prejudicial	Strickland governs by law in effect at trial; counsel need not anticipate changes in law; prior Strickland review (Lynch II) found no prejudice; claim is procedurally barred and meritless	Strickland test unchanged; claim procedurally barred and on merits fails — prior finding of no prejudice stands

Hurst v. Florida, 136 S. Ct. 616 (2016) (Supreme Court decision limiting judge-alone factfinding in capital sentencing)
Mullens v. State, 197 So. 3d 16 (Fla. 2016) (defendant who validly waives penalty-phase jury is not entitled to Hurst relief)
Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance-of-counsel test: deficiency and prejudice)
Lynch v. State, 841 So. 2d 362 (Fla. 2003) (direct appeal affirming convictions and death sentences)
Lynch v. State, 2 So. 3d 47 (Fla. 2008) (postconviction opinion addressing mitigation investigation and counsel performance)
Lynch v. Sec’y, Fla. Dep’t of Corrs., 776 F.3d 1209 (11th Cir. 2015) (federal habeas proceedings discussing facts, waiver, and mitigation issues)