State of Florida v. Raymond Morrison, Jr.
236 So. 3d 204
Fla.2017Background
- Raymond Morrison was convicted in 1998 of first‑degree murder, related crimes, and sentenced to death; convictions and death sentence were affirmed on direct appeal.
- Morrison filed a Rule 3.851 postconviction motion alleging numerous claims including ineffective assistance of counsel (guilt and penalty phases), Brady violations, newly discovered evidence, and intellectual disability; an evidentiary hearing was held.
- The postconviction court granted a new guilt phase and a new penalty phase based on several ineffective‑assistance claims, and denied or left unresolved other claims.
- The State appealed the grant of a new guilt phase; Morrison cross‑appealed denial of several claims and sought cumulative‑error relief.
- The Florida Supreme Court reversed the grant of a new guilt phase (finding no Strickland prejudice as to confessions and guilt‑phase investigation), affirmed the grant of a new penalty phase (finding counsel deficient and prejudicial for failing to investigate and present substantial mitigation), and affirmed denial of most other claims; it vacated the death sentence and remanded for a new penalty phase.
Issues
| Issue | Plaintiff's Argument (Morrison) | Defendant's Argument (State) | Held |
|---|---|---|---|
| 1) Counsel ineffective for failing to challenge voluntariness/reliability of Morrison's written statement | Counsel failed to investigate mental health, recent crack use, and propensity to falsely confess; evidence would have shown statement involuntary/unreliable | Statement was voluntary under the totality of circumstances; statement corroborated by independent facts (knife, coins, location); no Strickland prejudice | Reversed grant of new guilt phase on this claim — confession found voluntary; no reasonable probability outcome would differ |
| 2) Counsel ineffective for inadequate guilt‑phase investigation (alibi, timeline, intoxication, victim relationship) | Additional witnesses/evidence would have created reasonable doubt or undermined timeline/intoxication defenses | Existing trial evidence (including confession, physical evidence, witness placement) defeats prejudice showing | Reversed grant of new guilt phase — no Strickland prejudice from these investigative omissions |
| 3) Counsel ineffective for inadequate penalty‑phase investigation (mental health, social history) | Counsel failed to develop and present substantial mitigation (organic brain damage, adaptive deficits, childhood abuse, deprived upbringing) | Trial record contained some mitigation and experts; but trial counsel relied on prior counsel and did not fully investigate | Affirmed grant of new penalty phase — counsel performance deficient and prejudice shown; reasonable probability penalty outcome would differ |
| 4) Brady, newly discovered evidence, intellectual disability, cumulative error | Various suppressed or new items (condom, notes, witness statements, DNA, Brown’s posttrial admission) and ID claim asserting onset before 18 | Many items not material or were known/accessible to defense; DNA not newly discovered; ID claim failed on manifestation prong | Majority affirmed denial of Brady and newly discovered evidence and rejected ID claim; denied guilt‑phase cumulative error; concurrence would have remanded for further ID proceedings |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (ineffective assistance standard requiring deficient performance and prejudice)
- Miranda v. Arizona, 384 U.S. 436 (custodial interrogation warnings and waiver)
- Hall v. Florida, 134 S. Ct. 1986 (intellectual disability and holistic review beyond strict IQ cutoff)
- Gore v. State, 846 So.2d 461 (Florida case discussing Strickland framework)
- Baker v. State, 71 So.3d 802 (voluntariness of confessions and coercive‑conduct test)