Walker v. State, 88 So. 3d 128

Walker was convicted of 2003 first-degree murder, kidnapping, and aggravated battery resulting in death; sentenced to death.
Direct appeal upheld convictions and death sentence, later postconviction relief motion filed.
Postconviction court granted new penalty phase for ineffective penalty-phase counsel; guilt-phase claims denied.
Walker alleged two IAC failures: failing to object to blood-stain photos and failing to present involuntariness of confession.
State cross-appealed the penalty-phase relief; court affirmed a new penalty phase.
Penalty-phase evidence included bipolar disorder testimony and limited mitigation; postconviction evidence broadened mitigation showing drug abuse and family background.

Issue	Plaintiff's Argument	Defendant's Argument	Held
IAC for not objecting to blood-stain photos earlier	Walker	Walker	Denied; no prejudice shown.
IAC for not presenting involuntariness of confession	Walker	Walker	Denied; voluntariness previously upheld, no reasonable probability of different outcome.
Cumulative error claim	Walker	Walker	Denied; no basis for relief.
State cross-appeal on penalty-phase representation	State	Walker	Affirmed; defense penalty-phase performance found deficient; new penalty phase warranted.

Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (establishes two-prong Strickland test for ineffective assistance of counsel)
Bolin v. State, 41 So.3d 151 (Fla. 2010) (balances performance, prejudice; remains applicable in Florida postconviction review)
Sochor v. State, 883 So.2d 766 (Fla. 2004) (de novo review of legal conclusions in mixed determinations)
Connor v. State, 979 So.2d 852 (Fla. 2007) (facial sufficiency/summary denial framework for Rule 3.851 claims)
State v. Coney, 845 So.2d 120 (Fla. 2003) (pure questions of law reviewed de novo in evidentiary rulings)
Penry v. Lynaugh, 492 U.S. 302 (U.S. 1989) (relevance of defendant background to culpability)
Wiggins v. Smith, 539 U.S. 510 (U.S. 2003) (mandatory mitigation investigation in capital cases)