& SC14-873 Cornelius O. Baker v. State of Florida and Cornelius O. Baker v. Julie L. Jones, etc., 214 So. 3d 530

Background

Defendant Cornelius Baker was convicted of first-degree murder, home-invasion robbery with a firearm, kidnapping, and related offenses for the 2007 abduction and killing of Elizabeth Uptagrafft; jury verdicts and death sentence were affirmed on direct appeal.
At the penalty phase, the jury recommended death 9–3; the trial court found multiple aggravators (including pecuniary gain, HAC, and CCP) and several mitigators (brain damage/low intellectual functioning, abusive childhood, remorse, age 20).
Baker filed a Rule 3.851 postconviction motion raising ineffective-assistance and sentencing-structure challenges; the trial court denied relief after an evidentiary hearing where trial counsel testified.
While Baker’s case was final, the U.S. Supreme Court decided Hurst v. Florida, applying Ring principles and requiring jury findings for the facts necessary to impose death; Florida courts extended Hurst to many pre-Hurst final cases.
This Court held Hurst applies to Baker and found the penalty phase defective because the jury did not make the required unanimous findings and the recommendation was not unanimous, so harmless-error review failed.
The Court reversed the trial court’s denial of relief as to the penalty-phase constitutional claim, vacated Baker’s death sentence, and remanded for a new penalty phase; Baker’s habeas claims challenging appellate counsel’s omissions were denied.

Issues

Issue	Baker's Argument	State's Argument	Held
Whether Florida’s capital scheme requires unanimous jury findings of aggravators and a unanimous recommendation (Hurst/Ring claim)	Hurst/Ring requires unanimous jury findings of each aggravator and that aggravators are sufficient and outweigh mitigation; applies to Baker	Jury did not make findings but outcome remains valid or harmless	Court: Hurst applies; because recommendation was 9–3 and jury made no unanimous findings, error not harmless; vacates death sentence and orders new penalty phase
Whether trial counsel was ineffective for failing to proffer Baker’s letter of apology at penalty phase	Counsel’s failure prejudiced mitigation presentation	Letter was not decisive; other mitigation evidence presented	Not addressed on merits because new penalty phase ordered under Hurst (court did not resolve other penalty-phase issues)
Whether appellate counsel was ineffective for failing to supplement the record with an exhibit of medical/psych records used by defense psychologist	Missing exhibit undermined appellate review and proportionality analysis	Dr. Krop’s extensive testimony covered the exhibit’s contents; omission was cumulative and nonprejudicial	Denied — appellate counsel not ineffective; omission was cumulative and not prejudicial
Whether appellate counsel was ineffective for failing to include the full April 24, 2002 ACT report in the record	The report would have supported extreme emotional disturbance mitigation	Report was inconsistent with extreme disturbance claim and portions were covered in testimony; defendant did not preserve trial-court sentencing-order objection	Denied — omission not prejudicial and appellate counsel not ineffective; claim procedurally barred where applicable

Key Cases Cited

Baker v. State, 71 So.3d 802 (Fla. 2011) (prior direct-appeal opinion summarizing facts and trial/penalty-phase proceedings)
Hurst v. Florida, 136 S. Ct. 616 (U.S. 2016) (extending Ring; requiring jury findings for facts necessary to impose death)
Ring v. Arizona, 536 U.S. 584 (2002) (jury, not judge, must find aggravating facts that expose defendant to death)
Mosley v. State, 209 So.3d 1248 (Fla. 2016) (explaining Hurst remedial scope for defendants with final sentences)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective-assistance-of-counsel standard)
Pope v. Wainwright, 496 So.2d 798 (Fla. 1986) (standards for ineffective appellate counsel)