Taylor v. State, 62 So. 3d 1101

Taylor, under a death sentence for capital murder, challenged his conviction and sentence in a postconviction 3.850 motion and a habeas petition alleging ineffective appellate counsel.
The final amended postconviction motion raised twenty-one claims; an evidentiary Huff hearing occurred in 2005–2007.
DNA evidence from the trial was challenged with expert testimony and the defense sought to develop issues via amendments and closing arguments.
The postconviction court denied relief in a June 22, 2009 order; the State moved to strike portions of closing and amendments, which the court partially granted.
Taylor argued the amended motion falls under 3.850 (pre-2001 rule) rather than 3.851; the Florida Supreme Court held 3.850 governed the amendments.
The court addressed claims covering Frye/Daubert-type issues, Brady/Giglio material, newly discovered evidence, and ineffective assistance of trial and appellate counsel, culminating in an affirmance of denial of relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Amendment governance under 3.850 vs 3.851	Taylor argues 3.851 governs amendments after 2001.	State contends amendments remain governed by 3.850 for pre-2001 motions.	Amendment governed by 3.850; no abuse of discretion in denial.
Ineffective assistance regarding DNA evidence	Taylor asserts trial counsel failed on multiple DNA-related fronts.	State contends strategic decisions and trial tactics were reasonable.	Taylor failed to show deficient performance or prejudice.
Brady and Giglio claims	Taylor alleges suppression of DNA protocols, reports, and Zeigler's name, and false testimony.	State argues no material Brady/Giglio violations or suppression occurred.	No Brady or Giglio relief; claims not material.
Ineffective appellate counsel	Taylor claims appellate counsel failed to raise Frye-related and presumption-of-innocence issues.	State contends issues were not reversible or were meritless on direct appeal.	Appellate counsel not ineffective; claims denied.
Newly discovered evidence	Cowart's recanted testimony warrants a new trial.	State asserts recantation unreliable and not credible.	Recantation not credible; no new trial.

Gore v. State, 964 So.2d 1257 (Fla. 2007) (amended postconviction rules; 3.850 governs amendments)
Pagan v. State, 29 So.3d 938 (Fla. 2009) (standard for ineffective assistance claims; deference to trial strategy)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged standard for ineffective assistance)
Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (reasonableness of mitigation investigation; evaluation of strategy)
Occhicone v. State, 768 So.2d 1037 (Fla. 2000) (distinguishes strategic decisions from deficient performance)
Richardson v. State, 246 So.2d 771 (Fla. 1971) ( Richardson hearing procedures for discovery violations)
Dailey v. State, 965 So.2d 38 (Fla. 2007) (preservation of prosecutorial comment issues in context)
Belcher v. State, 961 So.2d 239 (Fla. 2007) (prescription on prosecutorial conduct and preservation)
Delva v. State, 575 So.2d 643 (Fla. 1991) (fundamental error doctrine for jury instructions)
Frye v. United States, 293 F. 1013 (D.C. Cir. 1923) (standard for admissibility of scientific evidence)
Zack v. State, 911 So.2d 1190 (Fla. 2005) (failure to order Frye hearing sua sponte evaluated)
Armstrong v. State, 862 So.2d 705 (Fla. 2003) (retrospective application of Frye analyses)
Hadden v. State, 690 So.2d 573 (Fla. 1997) (requirement of timely objection for evidentiary errors)
Archer v. State, 673 So.2d 17 (Fla. 1996) (reliability of trial objections to evidence)