Tina Lasonya Brown v. State of Florida, 143 So. 3d 392

Brown lured Audreanna Zimmerman to her trailer under false pretenses and, with two codefendants, tortured and killed her using a stun gun, crowbar, and gasoline, culminating in Zimmerman being set on fire and abandoned near Brown’s home.
Zimmerman identified Brown and others as her attackers at the hospital; she died sixteen days later from extensive burns and head trauma.
Evidence at trial included bloodstains on clothing and a stun gun, DNA on a headrest matching Zimmerman and Brown, and a medical examiner’s finding that the cause of death was multiple thermal injuries (homicide).
Miller and Lee were Brown’s codefendants; Miller, a minor at the time, could not be sentenced to death, and Lee pled guilty to second-degree murder under a plea agreement.
June 21, 2012, a jury convicted Brown of first-degree murder; at the penalty phase the court found three aggravators and multiple mitigators, imposing a death sentence on September 28, 2012.
The Florida Supreme Court affirmed the conviction and death sentence after reviewing CCP and other issues, proportionality, and Ring v. Arizona challenges.

Issue	Plaintiff's Argument	Defendant's Argument	Held
CCP (cold, calculated, and premeditated) established?	Brown contends the killing was not cold and calm.	Brown argues evidence shows preplanning and lack of moral justification.	CCP supported; evidence showed deliberate planning and calm reflection.
Extreme anger and rage negating CCP?	Brown asserts rage, not cold calculation, drove the murder.	Brown’s anger did not negate CCP given planning and restraint.	CCP upheld despite anger; murder shown as calculated.
Cocaine use on day of murder defeats CCP?	Brown’s cocaine use caused paranoia, impeding cool reflection.	Record shows Brown remained cognizant and calculated despite use.	Drug use did not preclude CCP; Brown was capable of deliberate action.
Proportionality of death sentence?	Sentence not proportionate given mitigating circumstances.	Aggravating factors outweigh mitigators, warranting death.	Death sentence proportionate given CCP, HAC, kidnapping aggravators overrode mitigators.
Ring v. Arizona applicability?	Ring requires jury unanimity and participation in sentencing.	Unanimous jury recommendation of death renders Ring inapplicable in this context.	Ring does not apply; jury unanimity achieved in sentencing phase; relief denied.

Lynch v. State, 841 So.2d 362 (Fla. 2003) (standard for reviewing CCP; must apply correct law rather than reweigh evidence)
Evans v. State, 800 So.2d 182 (Fla. 2001) (four-part test for CCP)
Turner v. State, 37 So.3d 212 (Fla. 2010) (domestic disturbance not a CCP bar; no domestic-dispute exception)