& SC14-1332 Clemente Javier Aguirre-Jarquin v. State of Florida & Clemente Javier Aguirre-Jarquin v. Julie L. Jones, etc.
202 So. 3d 785
| Fla. | 2016Background
- In 2006 Aguirre was convicted of two counts of first-degree murder (Cheryl Williams and Carol Bareis) and sentenced to death based primarily on forensic evidence (victims’ blood on Aguirre’s clothing, bloody shoe impressions matching his footwear, and a chef’s knife found between residences). The convictions and sentences were affirmed on direct appeal.
- Aguirre consistently maintained he found the bodies, handled the knife out of fear, and did not call police because he feared deportation. Trial testimony included Samantha Williams (victim’s daughter/granddaughter) placing Aguirre in the house previously and denying the family owned the murder-knife type.
- Postconviction DNA testing of 150 previously untested bloodstains revealed eight stains containing Samantha Williams’s DNA (not Aguirre’s) located in key, high-traffic areas and near victims’ blood and the bathroom the State alleged the killer used to clean up. This testing was newly available after trial.
- During postconviction proceedings, several witnesses testified that Samantha made multiple, spontaneous admissions on five occasions to four different people that she killed her mother and grandmother (including statements attributing the acts to ‘‘demons’’). These confessions came to light largely during and after the initial postconviction evidentiary hearing.
- The circuit court denied relief, ruling the successive claims were an abuse of process and that Samantha’s statements were inadmissible hearsay (and in any event would not probably produce an acquittal). The Florida Supreme Court reviewed only whether the cumulative newly discovered evidence warranted a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether newly discovered DNA and witness statements require a new trial | Aguirre: newly discovered DNA placing Samantha at key crime-scene locations plus multiple confessions weaken State’s case and create reasonable doubt | State: evidence either cumulative or inadmissible; circuit court found abuse of process and expert testimony still supports conviction | Court: Granted relief — cumulative newly discovered evidence would likely produce reasonable doubt; vacated convictions and remanded for new trial |
| Admissibility of third‑party out‑of‑court confessions (Samantha’s statements) | Aguirre: statements meet Chambers factors and are admissible as substantive evidence and impeachment | State: statements are hearsay and inadmissible; circuit court excluded them | Court: Statements admissible under Chambers and may be used substantively and to impeach Samantha |
| Abuse of process / procedural bar to successive postconviction motion | State/circuit court: Aguirre should have amended initial 3.851 rather than file successive motion | Aguirre: many statements and evidence surfaced only during/after the evidentiary hearing, justifying successive motion | Court: Declined to apply abuse‑of‑process bar; allowed consideration of later‑discovered confessions |
| Weight of conflicting forensic expert opinions and alibi evidence | State: forensic evidence and Samantha’s alibi (testimony) still support conviction; experts contradict Aguirre’s theory | Aguirre: postconviction experts and new DNA evidence undermine State’s forensic inferences and weaken alibi corroboration | Court: Conflicts exist but do not dispel reasonable doubt created by new DNA plus multiple confessions; new trial required |
Key Cases Cited
- Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (out‑of‑court confessions may be admissible where exclusion would violate defendant’s constitutional rights)
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (capital sentencing procedure regarding factfinding by jury)
- Aguirre‑Jarquin v. State, 9 So. 3d 593 (Fla. 2009) (direct‑appeal decision affirming convictions and sentence)
- Jones v. State, 709 So. 2d 512 (Fla. 1998) (Jones II) (standards for newly discovered evidence to obtain a new trial)
- Jones v. State, 591 So. 2d 911 (Fla. 1991) (Jones I) (requirement to consider all admissible newly discovered evidence and compare weight against trial evidence)
- Marek v. State, 14 So. 3d 985 (Fla. 2009) (newly discovered evidence suffices if it weakens case to create reasonable doubt)
- Swafford v. State, 125 So. 3d 760 (Fla. 2013) (requirement for cumulative analysis of admissible newly discovered evidence)
- Green v. State, 975 So. 2d 1090 (Fla. 2008) (standard of review for postconviction evidentiary findings)
- Bearden v. State, 161 So. 3d 1257 (Fla. 2015) (application of Chambers factors to third‑party confessions)