Timothy W. Fletcher v. State of Florida, 168 So. 3d 186

Fletcher escaped the Putnam County Jail with Doni Brown in April 2009 to avoid re-arrest and planned to rob Googe for funds.
They attempted to steal multiple vehicles before successfully taking Googe’s car and proceeding to her residence.
Googe died from manual strangulation during the burglary; Fletcher’s DNA was found under Googe’s nails, Brown’s was not.
Evidence linked to the escape and Googe murder included the getaway vehicles, weaponry, the safe, and the loot discarded at various locations.
Fletcher provided differing post-arrest confessions, initially blaming Brown and later offering alternate versions; DNA and other evidence tied him to the murder.
A jury convicted Fletcher of first-degree murder, escape, burglary, grand theft, and home-invasion robbery, and sentenced him to death after a penalty-phase proceeding with mitigating evidence from his family and psychologist witnesses.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Consolidation of related offenses proper?	Fletcher argues severance is required for fair determination.	State contends offenses were a single episode with a meaningful link.	Yes; crimes properly consolidated; no abuse of discretion.
Admissibility and invocation of post-arrest statements?	Statement about shackles was an invocation of rights.	Statement was not an invocation; Miranda waived.	Trial court properly denied suppression; waiver clarified by later Miranda warnings.
Improper prosecutorial comments during penalty phase?	Prosecutor’s remarks, including “send a message,” biased the jury.	Comments were within the bounds of closing argument and rebuttal.	Not fundamental error; harmless beyond a reasonable doubt.
Lack of remorse and nonstatutory aggravation evidence?	Prosecutor elicited lack-of-remorse evidence as aggravation.	Such evidence is improper but was limited and not dispositive.	Error was harmless beyond a reasonable doubt; cautioned against future use.

Fotopoulos v. State, 608 So.2d 784 (Fla. 1992) (whether acts are connected for consolidation by episodic or causal linkage)
Lugo v. State, 845 So.2d 74 (Fla. 2003) (meaningful relationship required for consolidation; prevent unwarranted severance)
Traylor v. State, 596 So.2d 957 (Fla. 1992) (interrogation must cease on invocation; equivocal invocations clarified by later warnings)
Delhall v. State, 95 So.3d 134 (Fla. 2012) (prosecutorial remarks during penalty phase—mitigation can be mischaracterized; need for caution)
Hayward v. State, 24 So.3d 17 (Fla. 2009) (victim-impact juxtaposition limits; no direct life-choices comparison in some contexts)