Snelgrove v. State, 107 So. 3d 242

Snelgrove was convicted of double murder of Glyn and Vivian Fowler in 2000; convictions upheld, death sentences reversed for penalty-phase errors, remanded for new penalty phase.
Second penalty phase included testing for mental retardation; WAIS-III score of 70 prompted renewed continuance request, denied.
Penalty-phase evidence included extensive crime-scene testimony, brain-imaging rebuttal, and expert opinions on mental state, addiction, and brain function.
Spencer hearing occurred after a year-long delay; experts debated IQ scores (70 vs 75) and whether MR was manifested before age 18.
Trial court found five aggravators and one statutory mitigator (extreme mental or emotional disturbance) plus several nonstatutory mitigators; two death sentences imposed.
On appeal, issues included continuance, MR determination, admissibility of video, jury instructions, cross-examination scope, victim impact, and weight of aggravators/mitigators; court affirmed sentences.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Continuance denial for MR testing	Snelgrove sought more time for MR testing before penalty phase.	Court abused discretion by delaying, allowing indefinite postponement.	No abuse; continuance proper given timing and evidence.
MR determination	Evidentiary MR claim should prevail; IQ evidence supports retardation.	Evidence insufficient to prove MR under three-prong test.	Snelgrove not mentally retarded; substantial evidence supports finding.
Video and CVSA in penalty phase	Video of interrogation and CVSA improperly admitted to bolster mitigation.	Evidence properly admissible to rebut mitigation, within §921.141.	Admissible; not abuse of discretion.
Victim impact and closing remarks	Prosecutor comments and victim-impact instruction improperly influenced jury.	Instructions and comments were proper and not reversible error.	No reversible error; instruction and comments acceptable.
Weight/consideration of aggravators and mitigators	Trial court misweighed aggravators or undervalued mitigate evidence.	Weighting and balancing within trial court's discretion; supported by record.	Death sentences proportionate; no abuse in weighing.

Doorbal v. State, 983 So.2d 464 (Fla.2008) (continuance abuse of discretion—delay caused by party)
Wyatt v. State, 641 So.2d 1336 (Fla.1994) (continuance denied when delay attributable to defendant)
Israel v. State, 837 So.2d 381 (Fla.2002) (undue prejudice standard for continuances in postconviction)
Coday v. State, 946 So.2d 988 (Fla.2006) (cross-examination breadth in penalty phase)
Phillips v. State, 984 So.2d 503 (Fla.2008) (IQ scores and MR considerations under 921.137)
Franqui v. State, 59 So.3d 82 (Fla.2011) (MR standard and evidence review)