Wayne C. Doty v. State of Florida, 170 So. 3d 731

Defendant Wayne C. Doty, serving life for a prior murder, pled guilty to killing fellow inmate Xavier Rodriguez in prison; jury recommended death 10–2 and trial court imposed death after weighing aggravators and mitigators.
The murder was planned: Doty obtained a homemade knife, lured Rodriguez, applied a chokehold, stabbed him, tied a ligature, and later confessed; medical testimony indicated strangulation and multiple stab wounds.
Trial court found three statutory aggravators: prior violent felony, committed while under sentence of imprisonment, and CCP (cold, calculated, premeditated); HAC was rejected. Court found several nonstatutory mitigators with varying weight and concluded aggravation outweighed mitigation.
Doty represented himself (Farretta) at stages, had standby counsel, and sought to limit or waive appellate review to expedite execution; the Supreme Court required appointed counsel to file adversarial briefing under Klokoc and Robertson but allowed pro se filings.
Appellate counsel raised four issues: alleged error in HAC jury instruction, permitting questioning on future dangerousness, Golden Rule testimony by the medical examiner, and challenge under Ring v. Arizona to Florida’s capital scheme. The Court also reviewed voluntariness of the guilty plea and proportionality of the death sentence independently.

Issue	Plaintiff's Argument (Doty)	Defendant's Argument (State)	Held
Voluntariness of guilty plea	Plea may not have been fully knowing/voluntary given self-representation	Plea colloquy and competency evaluation show plea was knowing, intelligent, voluntary	Plea was valid; conviction for first-degree murder affirmed
HAC jury instruction	Trial court erred by instructing jury on HAC though court later rejected HAC	Credible evidence supported submission to jury; harmless if error	No reversible error; instruction proper and harmless
Future dangerousness testimony	Court erred allowing Doty to elicit testimony implying future dangerousness	Doty voluntarily opened the door by choosing to elicit such testimony after warnings	Denied; invited error and informed waiver by Doty
Golden Rule testimony by ME	Medical examiner improperly invited jurors to imagine victim’s suffering (Golden Rule)	Testimony was brief, unobjected to; not fundamental error	Error acknowledged but not fundamental; claim denied
Ring v. Arizona challenge	Florida’s sentencing scheme violates Ring	Prior-violent-felony aggravator supports capital sentencing under Florida precedent	Denied; prior-violent-felony aggravator forecloses Ring-based relief

Klokoc v. State, 589 So. 2d 219 (Fla. 1991) (Florida Supreme Court has mandatory obligation to review death sentences despite defendant’s desire to waive appeal)
Robertson v. State, 143 So. 3d 907 (Fla. 2014) (refusing to recede from Klokoc; counsel must pursue adversarial appellate advocacy in death cases)
Farretta v. California, 422 U.S. 806 (U.S. 1975) (right to self-representation)
Ocha v. State, 826 So. 2d 956 (Fla. 2002) (when defendant pleads guilty to death-eligible offense, court must scrutinize voluntariness of plea)
Winkles v. State, 894 So. 2d 842 (Fla. 2005) (standards for knowing, intelligent, voluntary guilty plea in capital cases)
Miller v. State, 42 So. 3d 204 (Fla. 2010) (trial court may instruct jury on aggravator if credible evidence supports its consideration even if court later rejects the aggravator)
Ring v. Arizona, 536 U.S. 584 (U.S. 2002) (procedural holding on factfinding for capital sentencing; discussed as challenge to Florida scheme)