& SC16-56 Cary Michael Lambrix v. State of Florida and Cary Michael Lambrix v. Julie L. Jones, etc., 217 So. 3d 977

Background

Lambrix was convicted in 1986 of two counts of first‑degree murder for a 1983 double homicide and sentenced to death; his convictions and sentences became final in 1986.
After numerous direct and collateral proceedings over decades (state and federal), and multiple successive postconviction and habeas petitions, the Governor signed a new death warrant in 2015/2016, prompting a successive Rule 3.851 motion and a Rule 3.853 DNA testing motion.
The postconviction court summarily denied the successive motion and the DNA motion; Lambrix appealed and filed a habeas petition in this Court. The Court stayed his execution to consider the effect of Hurst v. Florida.
Lambrix raised claims including conflict of interest/Cronic, denial of a full and fair DNA hearing, inadequate postconviction proceedings, Eighth Amendment challenge to prolonged time on death row, Hurst/Ring Sixth Amendment claim, alleged bias by the postconviction judge, and inadequate clemency process.
The Court applied precedent (Asay v. State) holding Hurst not retroactive to convictions final before Hurst and rejected Lambrix’s other claims as untimely, procedurally barred, or meritless; it affirmed the denials and lifted the stay.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Conflict of interest / Cronic violation	Lambrix: an FBI report (received by prior counsel in 1999) shows defense counsel considered him difficult/untruthful, creating a conflict and warranting presumed prejudice under Cronic	State: claim is untimely/successive; the report was known in 1999; allegations do not show counsel was denied or withheld so as to trigger Cronic	Denied — claim procedurally barred as untimely; merits fail under Cronic because counsel was not effectively denied and no per se prejudice shown
DNA testing under Rule 3.853	Lambrix: testing tire iron, t‑shirt, and female victim’s clothing might produce exculpatory DNA and create reasonable doubt	State: evidence largely unavailable or previously tested (no blood on items), testing unlikely to change outcome given admissions and other evidence; defendant failed to show testing would exonerate or mitigate	Denied — motion facially insufficient; no reasonable probability testing would exonerate or mitigate
Adequacy of postconviction proceedings / scheduling order	Lambrix: December 2015 scheduling order impeded his ability to develop the record and litigate claims	State: scheduling order reasonable; claims are vague/conclusory; prior remedies/stays available if meritorious	Denied — claims conclusory and previously rejected; no basis for relief
Hurst / Ring Sixth Amendment claim and retroactivity	Lambrix: Hurst requires jury findings and entitles him to new penalty phase despite finality in 1986	State: Hurst is not retroactive to convictions final before Hurst per this Court’s precedent (Asay); prior Florida law controlled earlier appeals	Denied — Hurst not applied retroactively to Lambrix; habeas claim rejected

Key Cases Cited

Cronic v. United States, 466 U.S. 648 (1984) (creates narrow circumstances where prejudice is presumed because counsel was effectively denied)
Strickland v. Washington, 466 U.S. 668 (1984) (ineffective assistance standard requiring proof of deficient performance and prejudice)
Ring v. Arizona, 536 U.S. 584 (2002) (Sixth Amendment requires jury finding of aggravating factors necessary for death sentence)
Hurst v. Florida, 136 S. Ct. 616 (2016) (Florida sentencing scheme violated Sixth Amendment by not requiring jury to find facts necessary for death sentence)
Hurst v. State, 202 So.3d 40 (Fla. 2016) (Florida Supreme Court decision applying Hurst to Florida sentencing scheme)
Asay v. State, 210 So.3d 1 (Fla. 2016) (Florida Supreme Court ruling addressing Hurst retroactivity and limiting application to cases not final before Hurst)
Teague v. Lane, 489 U.S. 288 (1989) (framework governing retroactive application of new constitutional rules in collateral review)