& SC15-1233 Richard Knight v. State of Florida & Richard Knight v. Julie L. Jones, etc.
225 So. 3d 661
| Fla. | 2017Background
- In 2006 a jury convicted Richard Knight of two counts of first-degree murder (a mother and her 4‑year‑old) and unanimously recommended death for each; convictions and sentences were affirmed on direct appeal.
- Physical and forensic evidence tied Knight to the scene: victims’ blood on his clothes and knives, fingernail scrapings containing Knight’s DNA, and witness inmate testimony recounting a confession.
- Postconviction (Rule 3.851) proceedings challenged guilt‑phase and penalty‑phase counsel performance, Brady nondisclosures, constitutionality of a Florida Bar rule and lethal‑injection protocol, and sought habeas relief for alleged appellate counsel errors.
- The circuit court held an evidentiary hearing and denied relief; the Florida Supreme Court affirmed denial of the 3.851 motion and denied habeas corpus.
- The Court applied Strickland prejudice/deficiency analysis throughout, rejected Brady and Frye‑related claims, and held a Hurst v. Florida error harmless beyond a reasonable doubt (five‑justice majority), though two separate justices dissented on Hurst relief.
Issues
| Issue | Knight's Argument | State's Argument | Held |
|---|---|---|---|
| Ineffective assistance at guilt phase (failure to call Dr. Rudin) | Dr. Rudin would have undermined DNA evidence and changed verdict | Dr. Rudin’s later report supported the State; counsel reasonably withheld her testimony as strategy | Denied — counsel’s choice was reasonable and no prejudice shown under Strickland |
| Failure to seek Frye hearing on DNA methods | Frye hearing would have excluded unreliable DNA testing | Techniques used (PCR, STR) were generally accepted; Frye not warranted; hearing would not have excluded evidence | Denied — no deficient performance and no prejudice; methods were generally accepted |
| Penalty‑phase ineffective assistance (mitigation, mental‑health evidence) | Counsel failed to investigate/introduce sexual‑abuse history and failed to secure competent mental‑health expert | Counsel conducted a reasonable investigation, presented mitigation witnesses, retained experts and did not present unreliable reports | Denied — competent investigation and presentation; no Strickland prejudice shown |
| Brady nondisclosure claims (Noppinger memo, jail logs, Greaves report) | Withheld impeachment/exculpatory materials that could have impeached State witnesses | Materials were immaterial, unrelated, or not shown to be known/suppressed by prosecutor; other strong inculpatory evidence existed | Denied — postconviction court’s findings supported: no favorable, suppressed, material evidence under Brady |
| Hurst error (jury fact‑finding at penalty phase) | Knight argued death sentence unconstitutional under Hurst and sought resentencing or life sentence under §775.082(2) | State: Hurst error harmless because jury unanimously recommended death and aggravators were overwhelming | Denied relief on resentencing; majority held Hurst error harmless beyond a reasonable doubt and affirmed death; separate opinions would have vacated and imposed life or ordered new penalty phase |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (establishes two‑prong ineffective‑assistance test)
- Frye v. United States, 293 F. 1013 (D.C. Cir.) (standard for novel scientific evidence)
- Wiggins v. Smith, 539 U.S. 510 (reasonableness of mitigation investigation under Strickland)
- Brady v. Maryland, 373 U.S. 83 (prosecution duty to disclose favorable evidence)
- Hurst v. Florida, 136 S. Ct. 616 (jury fact‑finding requirement for death penalty)
- Hurst v. State, 202 So.3d 40 (Fla.) (Florida post‑Hurst remedial framework)
- Davis v. State, 207 So.3d 142 (Fla.) (held certain Hurst errors harmless where jury unanimously recommended death)
- DiGuilio v. State, 491 So.2d 1129 (Fla.) (harmless‑error analysis guidance)