& SC14-567 Ronald Knight v. State of Florida & Ronald Knight v. Julie L. Jones, etc.
211 So. 3d 1
Fla.2016Background
- Ronald Knight was convicted after a nonjury trial of first‑degree murder (1993 killing of Richard Kunkel) and sentenced to death; he was represented at guilt phase pro se with standby counsel and by counsel at penalty phase.
- Knight’s direct appeal affirmed convictions and sentence; later he filed a Rule 3.850 postconviction motion and a habeas petition.
- Postconviction proceedings raised 21 claims (Brady/Giglio, jury/counsel waivers, ineffective assistance, Ake, Richardson/public‑records issues, double jeopardy/speedy‑trial re: an earlier nolle prosequi, lethal injection, etc.); evidentiary hearing held on most claims.
- The postconviction court denied relief; Knight appealed and sought habeas relief in the Florida Supreme Court.
- The Court affirmed denial of postconviction relief and denied habeas relief, rejecting claims for ineffective assistance (mitigation investigation; failure to move to discharge), Richardson violations, self‑representation violation, waiver invalidity, and appellate counsel ineffectiveness; lethal injection claim summarily rejected.
Issues
| Issue | Plaintiff's Argument (Knight) | Defendant's Argument (State) | Held |
|---|---|---|---|
| I.A: Ineffective assistance — mitigation investigation | Penalty counsel failed to investigate and present additional mitigation (mental health, childhood, substance abuse) and new experts would have aided penalty phase. | Postconviction court: trial experts covered mitigation; new experts did not change diagnosis or materially alter outcome; many lay witnesses were unavailable or unreliable. | No deficient performance or prejudice; claim denied. |
| I.B: Ineffective assistance — failure to move to discharge (double jeopardy/speedy trial) | Counsel should have moved to discharge based on jury sworn in 1994 case (double jeopardy) or speedy‑trial violations from 1994 proceedings. | Record shows jury was not sworn in 1994 (no jeopardy), continuances attributable to defense and witness intimidation caused nolle prosequi; no basis for dismissal. | Motion to dismiss would be meritless; counsel not ineffective. |
| I.C: Ineffective assistance — Richardson/public‑records | State withheld 1994 records, accomplice statements, and ME investigator report that could have impeached witnesses; counsel failed to raise Richardson. | Many documents were produced or used at trial for impeachment; omitted materials would not have produced different outcome; claim procedurally barred as trial‑court error on direct appeal. | No prejudice shown; claim denied. |
| II: Reappointment of CCRC‑South over objection / self‑representation | Reappointment deprived Knight of right to self‑representation in postconviction. | Postconviction court permissibly balanced Knight’s asserted self‑determination with the court’s duty to ensure fair, efficient postconviction review; Knight was not unequivocal in seeking self‑representation and was offered options. | Reappointment not an abuse of discretion; no violation. |
| III: Validity of waivers of counsel and jury (guilt & penalty phases) | Waivers were not knowingly, intelligently, and voluntarily made. | Waivers were confirmed in writing and on the record, Knight had pretrial experience and counsel advice (standby counsel); issue was raised and rejected on direct appeal or should have been. | Waivers found knowing, intelligent, voluntary; claim procedurally barred or meritless. |
| IV: Habeas — appellate counsel ineffective (jury waiver, incomplete record) | Appellate counsel failed to raise jury‑waiver problems and ensure a complete trial record (including 1994 materials, accomplice depositions). | Issues lacked merit (waivers valid); missing materials would not have changed outcome or were conclusory; appellate counsel not ineffective for failing to raise meritless claims. | Habeas relief denied for ineffective appellate assistance. |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (test for ineffective assistance of counsel)
- Knight v. State, 770 So. 2d 663 (Fla. 2000) (direct appeal affirming conviction and death sentence)
- Richardson v. State, 246 So. 2d 771 (Fla. 1971) (discovery obligations; Richardson doctrine)
- Lambrix v. State, 124 So. 3d 890 (Fla. 2013) (limits on self‑representation in postconviction)
- Mines v. State, 390 So. 2d 332 (Fla. 1980) (requirements for knowing jury‑waiver)
- Guzman v. State, 721 So. 2d 1155 (Fla. 1998) (valid waiver where record shows inquiry and written waiver)
- Turner v. State, 37 So. 3d 212 (Fla. 2010) (double jeopardy attaches when jury is impaneled and sworn)