& SC16-6 John Lee Hampton v. State of Florida and John Lee Hampton v. Julie L. Jones, etc.
219 So. 3d 760
| Fla. | 2017Background
- In 2007 Hampton was charged with first-degree murder after the nude, violently-injured body of Renee McKinness was found; DNA and physical evidence linked Hampton to the scene and semen in the victim matched Hampton.
- Hampton gave multiple, inconsistent videotaped statements to police admitting to killing the victim; at trial he recanted and testified he did not kill her. Jury convicted Hampton of first-degree murder; recommended death 9–3.
- Trial court found three aggravators (prior felony/probation, murder during commission of robbery/sexual battery/burglary, and HAC) and imposed death; trial court gave limited weight to multiple nonstatutory mitigators.
- Hampton filed a Rule 3.851 postconviction motion alleging, inter alia, ineffective assistance of counsel (competency stipulation, trial preparation, redaction failures), intellectual disability, and penalty-phase mitigation failures; an evidentiary hearing was held.
- The postconviction court denied relief on all claims; Hampton appealed and also petitioned for habeas corpus; the Florida Supreme Court affirmed most guilt-phase ineffectiveness rulings and the intellectual-disability determination but granted habeas and vacated the death sentence under Hurst, ordering a new penalty phase.
Issues
| Issue | Plaintiff's Argument (Hampton) | Defendant's Argument (State/Trial Counsel) | Held |
|---|---|---|---|
| Ineffective assistance — stipulation to competency / failure to obtain additional evaluator | Counsel should not have stipulated to Dr. Rothschild’s competency finding; a tiebreaker expert would have shown incompetence | Counsel reasonably relied on Dr. Rothschild (and their own interactions); no reasonable grounds to continue contesting competency | No ineffective assistance; even if deficient, no prejudice (later evaluator also found competency) |
| Videotaped interrogation — admission of outstanding warrant | Inclusion of references to Hampton’s outstanding warrant prejudiced jury | Reference explained Hampton’s avoidance of police; jury would have learned of warrant from Hampton’s testimony anyway | Counsel possibly deficient for not redacting, but no prejudice—outstanding warrant would have been revealed during trial and overwhelming guilt evidence existed |
| Videotaped interrogation — prohibition on consulting defendant during recess | Court’s recess ban denied Hampton needed counsel; counsel ineffective for not objecting | Counsel used recess strategically to negotiate limitation on cross-examination about sex-offender status; unlike Thompson, consultation denial was not shown | No ineffective assistance; strategy reasonable and no demonstrated prejudice |
| Videotaped interrogation — failure to redact inflammatory detective comments | Comments were prejudicial and should have been redacted | Counsel reasonably preserved comments to show interrogation pressure and explain inconsistent statements; false-confession expert did not find coercion but strategy aimed to undercut police focus | No ineffective assistance; even if deficient, no prejudice given overwhelming forensic and testimonial evidence |
| Intellectual disability | Hampton argued IQ and adaptive deficits warrant bar to execution; counsel ineffective for not raising it | State argued IQ testing and records show malingering and premorbid functioning inconsistent with intellectual disability; counsel had no good-faith basis to advance the claim | Hampton failed to prove intellectual disability (subaverage IQ, adaptive deficits, onset <18); counsel not ineffective for not raising it |
| Hurst error / constitutionality of death sentence | Jury did not make unanimous factual findings required post-Hurst; sentence must be vacated or harmlessness proven beyond reasonable doubt | State must prove Hurst error harmless beyond a reasonable doubt | Hurst applies retroactively; because jury vote was nonunanimous (9–3) and factual findings (e.g., HAC, felony-murder aggravator) unclear/unanimous, error not harmless — death sentence vacated and new penalty phase ordered |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (establishes Miranda warnings requirement for custodial interrogation)
- Strickland v. Washington, 466 U.S. 668 (two-prong test for ineffective assistance of counsel)
- Hurst v. State, 202 So.3d 40 (Fla. 2016) (Florida decision applying Sixth Amendment jury-findings requirement to capital sentencing)
- Ring v. Arizona, 536 U.S. 584 (holds that a jury must find every fact necessary to increase a defendant’s authorized punishment)
- Spencer v. State, 615 So.2d 688 (Fla. 1993) (procedural context for sentencing hearing and mitigation presentation)
- Schoenwetter v. State, 46 So.3d 535 (Fla. 2010) (prejudice inquiry where Strickland not satisfied)
- Bruno v. State, 807 So.2d 55 (Fla. 2001) (standard of review for postconviction ineffectiveness findings)