Victor Guzman v. State of Florida, 214 So. 3d 625

Background

Victim Severina Fernandez, an 80-year-old woman, was found stabbed to death in her Miami apartment on December 9, 2000; her clothing was torn and circumstances suggested a sexual assault or attempted sexual assault.
Male DNA was found in multiple bloodstains and on a cup at the scene; later testing matched Victor Guzman with extremely low random-match probabilities (1 in 153 trillion for blood profile; 1 in 5,099,000 for the cup mixture).
Guzman was interviewed by police in 2004, waived Miranda rights, denied involvement, but said he was “sorry” several times; he later invoked counsel. Buccal swabs obtained from Guzman confirmed the DNA match.
No eyewitnesses, no confession, no murder weapon; prosecution’s case relied heavily on DNA and forensic pathology (58 stab/incised wounds, defensive wounds, blunt trauma, fractured hyoid), supporting premeditation and felony-murder (attempted sexual battery) theories.
Jury convicted Guzman of first-degree murder; at penalty phase the jury recommended death 7–5. Trial court found multiple aggravators (HAC, prior violent felony, attempted sexual battery, victim vulnerability) and sentenced Guzman to death.
On appeal the Florida Supreme Court affirmed guilt but vacated the death sentence and remanded for a new penalty phase under Hurst v. Florida and related Florida precedent because the jury’s recommendation was nonunanimous.

Issues

Issue	Guzman’s Argument	State’s Argument	Held
Whether brief references at trial to jail/DNA match required a mistrial	References implied Guzman was incarcerated for other crimes or that his DNA was already in an offender database, prejudicing the jury	Statements were brief, inadvertent, and in context referred to the ongoing investigation; jury was instructed to disregard	Denied; no abuse of discretion (no mistrial)
Whether prosecutor’s closing remarks (inflaming language) entitled Guzman to relief	Prosecutor’s emotive language inflamed jury and was improper	Even if improper, comments did not rise to fundamental error	Denied; not fundamental error
Whether prosecutor shifted burden / commented on defense silence during closing	Prosecutor’s questions and hypotheticals shifted burden to Guzman and improperly commented on his silence/apology	DNA and lab testimony rebut defense contamination/mistake theory; Guzman waived right to remain silent when he spoke to detectives; remarks were permissible response to defense theory	Denied as to guilt-phase relief; comments not fundamental error
Sufficiency of the evidence for first-degree murder (premeditation / felony murder)	Guzman argued contamination/mistake could explain DNA match	State relied on multiple visible bloodstains matching Guzman throughout the apartment, forensic inferences (clean-edge stab wounds, sink blood), and corroborative pathology; no reasonable hypothesis of innocence established	Affirmed conviction: competent, substantial circumstantial evidence supports premeditated and felony-murder theories
Whether Hurst and Florida precedent require relief from death sentence given nonunanimous recommendation	Guzman argued his death sentence violates Sixth Amendment as interpreted in Hurst	State argued error might be harmless	Death sentence vacated; remand for new penalty phase because jury did not unanimously find aggravators or unanimously recommend death

Key Cases Cited

Hurst v. Florida, 136 S. Ct. 616 (U.S. 2016) (Florida’s sentencing scheme violated Sixth Amendment jury factfinding requirements)
Hurst v. State, 202 So. 3d 40 (Fla. 2016) (Florida Supreme Court interpreting Hurst to require unanimous jury findings on aggravators, sufficiency, and that aggravators outweigh mitigation)
Gosciminski v. State, 132 So. 3d 678 (Fla. 2013) (standard of review for denial of mistrial — abuse of discretion)
Braddy v. State, 111 So. 3d 810 (Fla. 2012) (contextual interpretation of testimony that might imply prior bad acts)
Twilegar v. State, 42 So. 3d 177 (Fla. 2010) (circumstantial-evidence standard and need to exclude reasonable hypotheses of innocence)
Snipes v. State, 733 So. 2d 1000 (Fla. 1999) (reasonable juror may infer defendant was in custody for the charged offense)
Fletcher v. State, 168 So. 3d 186 (Fla. 2015) (brief, isolated, inadvertent references to prior imprisonment may not require mistrial)
Orme v. State, 677 So. 2d 258 (Fla. 1996) (appellate standard: view record in light most favorable to prevailing theory)
Jackson v. State, 180 So. 3d 938 (Fla. 2015) (multiple, deliberate stab wounds can support premeditation)
Warmington v. State, 149 So. 3d 648 (Fla. 2014) (prosecutor may not shift burden of proof to defendant)