Rodgers v. State
113 So. 3d 761
| Fla. | 2013Background
- Rodgers was convicted in 2001 of first-degree murder of Teresa Henderson and sentenced to death.
- Direct appeal affirmed; the court noted the murder occurred after a confrontation at a daycare; multiple witnesses observed events.
- During penalty, prior felonies and two manslaughter convictions were admitted; multiple experts testified about mental status and retardation.
- In 2009 Rodgers filed a postconviction motion under Florida Rule 3.851 with an evidentiary hearing in 2011.
- Postconviction court denied relief and Rodgers appeals, challenging four ineffective-assistance claims and a waiver regarding jail clothing.
- The Florida Supreme Court affirms, holding no reversible error in the postconviction proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for alleged brain-damage evidence | Rodgers argues trial counsel should have obtained neuropsychological testing. | State contends existing expert evaluations were reasonable; no prejudice shown. | No deficient performance; no prejudice established. |
| Ineffective assistance regarding child witnesses | Rodgers claims counsel failed to challenge competency and erred in cross-examining child witnesses. | Counsel's competency decisions and limited cross-examination were reasonable strategic choices. | No prejudice; competency inquiries and cross-examination deemed reasonable. |
| Ineffective assistance regarding ownership of murder weapon | Defense should have admitted ATF trace showing gun ownership to ex-husband via a custodian/witness. | Insufficient predicate; no admissible business-record certification; prejudice not shown. | No deficient performance or prejudice; evidence would not alter outcome. |
| Waiver of wearing jail clothing during penalty phase | Rodgers’ waiver of right to wear jail clothing was involuntary; counsel ineffective for advice. | Waiver issue procedurally barred; if considered, strategic decision to wear jail clothing was reasonable. | Waiver issue procedurally barred; no ineffective assistance; decision reasonable. |
Key Cases Cited
- Darling v. State, 966 So.2d 366 (Fla. 2007) (deferring to qualified mental-health expert evaluations in capital cases)
- Sired v. State, 502 So.2d 1223 (Fla. 1987) (reliance on expert evaluations by defense)
- Stewart v. State, 37 So.3d 243 (Fla. 2010) (courts may rely on defense mental-health experts)
- Floyd v. State, 18 So.3d 432 (Fla. 2009) (competency of child witnesses; strategic cross-examination limits)
- Lloyd v. State, 524 So.2d 396 (Fla. 1988) (infant witness competency criteria)
- Carratelli v. State, 961 So.2d 312 (Fla. 2007) (competency issues in child testimony)
- Owen v. State, 986 So.2d 534 (Fla. 2008) (mental health mitigation and calculated murder—additional mitigation considerations)
- Everett v. State, 54 So.3d 464 (Fla. 2010) (limitations of certain mental health mitigations)
- Hoskins v. State, 965 So.2d 1 (Fla. 2007) (implications of mental state on mitigation evidence)
- Cherry v. State, 781 So.2d 1040 (Fla. 2000) (gun ownership and evidence considerations in capital cases)
- Estelle v. Williams, 425 U.S. 501 (U.S. Supreme Court, 1976) (compulsion to wear jail garb during trial)