& SC14-881 Charles L. Anderson v. State of Florida and Charles L. Anderson v. Julie L. Jones, etc.
220 So. 3d 1133
| Fla. | 2017Background
- Charles Anderson was convicted in 1999 of first‑degree murder for the death of his stepdaughter Keinya Smith and sentenced to death; conviction affirmed on direct appeal in Anderson v. State, 841 So.2d 390 (Fla. 2003).
- Key evidence: eyewitness reports of a car (similar to Anderson’s) running over a person; damage and grease/tires/fibers on Anderson’s car; one spot of blood on a car seat matching Keinya’s DNA; Anderson admitted picking her up and admitted prior sexual abuse for which he was on probation.
- Anderson filed a Rule 3.851 postconviction motion raising claims including ineffective assistance of guilt‑phase counsel for not using forensic experts, destruction/failure to preserve evidence (Brady/Trombetta/Youngblood theories), challenge based on the 2009 NAS forensic report, and Ring/Hurst sentencing error; trial court held an evidentiary hearing on a subset of claims and summarily denied others.
- Postconviction appeal: Florida Supreme Court affirmed denial as to guilt/conviction issues (rejecting ineffective‑assistance and evidence‑preservation claims), rejected NAS report as newly discovered evidence, but held Hurst error warranted relief.
- Court vacated Anderson’s death sentence and remanded for a new penalty phase because the jury’s recommendation had not been unanimous and Hurst v. Florida requires jury findings of aggravators beyond a reasonable doubt and unanimous jury determinations under Florida law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance for failing to retain/consult forensic experts (tires, blood, grease, fibers) | Anderson: counsel was deficient for not using defense experts to challenge equivocal physical evidence and Frye admissibility | State: counsel cross‑examined prosecution experts, no Frye basis for hearing on trace evidence, allegations conclusory and fail to show prejudice under Strickland | Denied—summary denial affirmed; counsel’s performance not shown deficient or prejudicial; cross‑examination and record rebut claims |
| Failure to preserve/deterioration of evidence (Brady/Trombetta/Youngblood) | Anderson: posttrial storage destroyed or degraded car, tire casts, and clothing, preventing retesting and showing bad faith suppression | State: no showing evidence had apparent exculpatory value before deterioration; allegations of bad faith conclusory; mere deterioration insufficient | Denied—no Brady/Trombetta/Youngblood relief; plaintiff failed to plead apparent exculpatory value or bad faith |
| 2009 National Academy of Sciences report as newly discovered evidence | Anderson: NAS report shows forensic science used at trial is unreliable and constitutes newly discovered evidence | State: Florida precedent holds the NAS report is not newly discovered evidence for postconviction relief | Denied—NAS report not newly discovered evidence per settled Florida authority |
| Ring/Hurst sentencing error (nonunanimous jury recommendation) | Anderson: death sentence unconstitutional under Ring and subsequent Hurst decisions requiring jury findings | State: challenged retroactivity/harmlessness; jury recommendation was non‑unanimous | Relief granted as to penalty—death sentence vacated and new penalty phase ordered under Hurst; conviction affirmed |
Key Cases Cited
- Anderson v. State, 841 So.2d 390 (Fla. 2003) (direct‑appeal opinion recounting facts and affirming conviction and sentence)
- Strickland v. Washington, 466 U.S. 668 (1984) (establishing ineffective‑assistance two‑prong test)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution duty to disclose favorable, material evidence)
- California v. Trombetta, 467 U.S. 479 (1984) (limits duty to preserve evidence to items with apparent exculpatory value)
- Arizona v. Youngblood, 488 U.S. 51 (1988) (due process requires bad faith to establish claim when potentially useful evidence is lost)
- Hurst v. Florida, 136 S. Ct. 616 (2016) (jury, not judge, must find facts necessary to impose death sentence)
- Ring v. Arizona, 536 U.S. 584 (2002) (Sixth Amendment requires jury finding of aggravating factors supporting death penalty)
- Daubert v. Merrell Dow Pharm., 509 U.S. 579 (1993) (federal standard for admissibility of scientific expert testimony)
- Frye v. United States, 293 F. 1013 (D.C. Cir. 1923) (general acceptance test for novel scientific evidence)