& SC16-399 Matthew Lee Caylor v. State of Florida and Matthew Lee Caylor v. Julie L. Jones, etc.
218 So. 3d 416
| Fla. | 2017Background
- Matthew Caylor was convicted (jury trial) of first-degree murder, sexual battery with great force, and aggravated child abuse for the 2008 killing of 13‑year‑old Melinda Hinson; jury recommended death 8–4 and trial court imposed death.
- Caylor confessed to police, describing sexual activity with the victim followed by strangulation; forensic evidence (DNA, ligature/strangulation marks, bleeding) corroborated sexual assault and strangulation.
- On direct appeal this Court affirmed convictions and sentence; U.S. Supreme Court denied certiorari in 2012.
- Postconviction Rule 3.851 proceedings raised multiple ineffective‑assistance and mitigation claims; the trial court granted an evidentiary hearing on limited issues (including juror challenge and mitigation investigation) but ultimately denied relief.
- Caylor filed a habeas petition raising (1) a statutory argument under section 775.082(2), (2) entitlement to a new penalty phase under Hurst v. Florida because the jury’s death recommendation was non‑unanimous, and (3) appellate counsel’s failure to raise an Ake claim.
- The Court affirmed denial of 3.851 relief (including counsel’s failure to strike Juror Weaver), but granted habeas relief: vacated the death sentence and remanded for a new penalty phase under Hurst; rejected the section 775.082(2) argument.
Issues
| Issue | Caylor's Argument | State's Argument | Held |
|---|---|---|---|
| Ineffective assistance for failing to challenge Juror Weaver (3.851) | Juror Weaver expressed uncertainty about impartiality, knew a witness (family connection), and had been a crime victim; counsel should have struck her. | The voir dire record shows rehabilitation: Weaver later said she could be fair and impartial and would evaluate the witness like others; no actual bias shown. | Denied — court found record refutes actual bias and counsel not ineffective. |
| Entitlement to new penalty phase under Hurst v. Florida (habeas) | Caylor argued Hurst requires unanimous jury findings and his non‑unanimous (8–4) recommendation renders his death sentence unconstitutional. | State implicitly argued error harmless or that Hurst doesn't apply to his case. | Granted — Hurst applies; jury did not make unanimous findings and recommendation was non‑unanimous, so error not harmless; death sentence vacated and new penalty phase ordered. |
| Section 775.082(2) statutory claim (habeas) | Statute requires commutation to life without parole for all death‑sentenced defendants after Hurst. | Florida precedent rejects automatic commutation under that statute post‑Hurst. | Denied — Court follows its prior ruling that the statute does not mandate automatic commutation. |
| Ineffective assistance of appellate counsel for not raising Ake on direct appeal (habeas) | Appellate counsel was ineffective for failing to raise an Ake claim. | If Hurst relief is granted, other claims need not be resolved on habeas now; also no prejudice shown. | Not reached substantively — Court did not address Ake claim because Hurst relief granted. |
Key Cases Cited
- Caylor v. State, 78 So.3d 482 (Fla. 2011) (direct‑appeal opinion describing facts, convictions, and trial court sentencing findings)
- Hurst v. Florida, 136 S.Ct. 616 (U.S. 2016) (Florida death‑penalty scheme unconstitutional for judge‑centric findings)
- Hurst v. State, 202 So.3d 40 (Fla. 2016) (Florida interpretation requiring unanimous jury findings for aggravators and weighing)
- Mosley v. State, 209 So.3d 1248 (Fla. 2016) (application of Hurst to defendants whose sentences were final after Ring)
- Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda warnings and waiver)
- Ake v. Oklahoma, 470 U.S. 68 (U.S. 1985) (right to psychiatric assistance for indigent defendant when sanity is at issue)
- Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (jury must find aggravating factors necessary for death sentence)
- Carratelli v. State, 961 So.2d 312 (Fla. 2007) (to prevail on jury‑selection ineffective‑assistance claim defendant must show an actually biased juror served)
- Huff v. State, 622 So.2d 982 (Fla. 1993) (procedure for preliminary review of postconviction claims)