Stephens v. Secretary, Florida Department of Corrections
2012 U.S. App. LEXIS 8859
| 11th Cir. | 2012Background
- Stephens, a Florida prisoner on death row, challenged a federal habeas corpus petition under 28 U.S.C. §2254 after state court denial.
- He was convicted of armed robbery and first-degree murder for crimes committed during a 1997 home invasion that involved kidnapping Sparrow III and three other occupants.
- Sparrow III died in a hot car, with contested testimony on whether death was due to asphyxiation or hyperthermia; medical experts disputed the cause of death.
- The Florida jury recommended death for the murder; the trial court sentenced Stephens to death consistent with the verdict.
- The Florida Supreme Court affirmed Stephens’ convictions and sentences on direct appeal and denied post-conviction relief; the federal petition was denied by the district court.
- The Eleventh Circuit reviewed the denial de novo under 28 U.S.C. §2254(d), addressing proportionality, trial-counsel effectiveness, and penalty-phase claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Proportionality under Enmund/Tison | Stephens contends death disproportional under Enmund and Tison. | Florida Supreme Court applied Tison/Enmund to uphold death sentence. | Not contrary or unreasonable application; proportionality upheld. |
| Ineffective assistance at guilt phase | Counsel rendered deficient performance across multiple guilt-phase actions. | Florida Supreme Court found no prejudice under Strickland for the claimed deficiencies. | No reversible error; claims not shown to prejudice the trial. |
| Ineffective assistance at penalty phase | Counsel failed to investigate mitigating evidence and improperly conceded aggravators. | Strategic decisions and trial strategy supported by record; no prejudice shown. | No reversible error; penalties affirmed. |
| Conflict of interest/delegation to co-defendant's counsel | Counsel operated under conflict and delegated duties to co-defendant's attorney. | Counsel acted in Stephens' interests; no actual conflict proven. | No reversible error; not an unreasonable application of law. |
Key Cases Cited
- Enmund v. Florida, 458 U.S. 782 (U.S. 1982) (death penalty in felony murder requires intent or major participation with reckless indifference)
- Tison v. Arizona, 481 U.S. 137 (U.S. 1987) (major participation plus reckless indifference can sustain death penalty)
- Hill v. Lockhart, 474 U.S. 52 (U.S. 1985) (prejudice standard for guilty-plea claims under Strickland)
- Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
- United States v. Cronic, 466 U.S. 648 (U.S. 1984) (presumption of prejudice not required where there was no adversarial testing)
- Skilling v. United States, 130 S. Ct. 2896 (U.S. 2010) (affirmative consideration of pretrial publicity and juror impartiality)
- Knowles v. Mirzayance, 556 U.S. 111 (U.S. 2009) (doubly deferential review for Strickland claims in §2254 cases)
- Williams v. Allen, 542 F.3d 1326 (11th Cir. 2008) (necessity of investigating mitigating evidence in penalty phase)
- Chandler v. United States, 218 F.3d 1305 (11th Cir. 2000) (strategic decisions may be reasonable even if not thoroughly investigated)
- Haliburton v. Sec’y for Dep’t of Corr., 342 F.3d 1233 (11th Cir. 2003) (defense strategy to humanize defendant can be reasonable)