Simmons v. State, 105 So. 3d 475

Simmons was convicted of first‑degree murder, kidnapping, and sexual battery; the jury recommended death for the murder and the court imposed death for the murder and life for other charges.
Direct appeal affirmed most issues but found eyewitness identification methods suggestive yet admissible under totality of circumstances.
Simmons filed a 3.851 postconviction motion; an evidentiary hearing was held with 43 witnesses and numerous exhibits.
The circuit court denied postconviction relief in part and Simmons pursued a habeas petition in this Court.
The Court affirms guilt-phase claims but reverses on penalty-phase relief, vacates the death sentence, and remands for a new penalty phase based on inadequate mitigation investigation.
The Court also denies the habeas petition challenging execution and appellate-counsel claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Effect of trial counsel’s suppression objections	Simmons argues coercive interrogation produced involuntary statements.	State contends statements were voluntary and defense didn’t prove coercion.	Guilt phase relief denied; no prejudice shown.
Adequacy of guilt‑phase mitigation/Brady‑Giglio claims	State withheld/exploited faulty DNA/testing and false testimony; mitigation was underdeveloped.	Prosecution did not knowingly withhold; testimony not material.	Brady/Giglio claims denied; no reversible error in guilt phase.
Penalty phase—failure to investigate/present mitigating evidence	Counsel failed to uncover substantial mental/childhood mitigation and brain‑injury evidence.	Strategic choice to present limited mitigation was reasonable under the circumstances.	Penalty‑phase relief granted; death sentence vacated and remanded for new penalty phase.
Habeas claims adjudication	Mental illness/defects entitle bar on execution; appellate counsel ineffectiveness claims.	Uniform precedents reject mental‑illness as per se bar; appellate failures not shown to undermine results.	Habeas petition denied.

Strickland v. Washington, 466 U.S. 668 (1984) (standard for ineffective assistance of counsel)
Porter v. McCollum, 559 U.S. 30 (2009) (necessity of meaningful mitigation presentation in capital case)
Wiggins v. Smith, 539 U.S. 510 (2003) (duty to conduct thorough mitigation investigation)
Hurst v. State, 18 So.3d 975 (Fla. 2009) (weight of mitigation and failure to present it)
Rose v. State, 675 So.2d 567 (Fla. 1996) (mitigation strategy must be informed by full information)
Bradley v. State, 787 So.2d 732 (Fla. 2001) (standard for sufficiency of evidence review)