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William James Deparvine v. State of Florida
146 So. 3d 1071
| Fla. | 2014
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Background

  • William Deparvine was convicted of two counts of first-degree murder and one count of armed carjacking for the 2003 Van Dusen killings and sentenced to death.
  • The Florida Supreme Court affirmed direct appeal convictions and sentences after evaluating trial errors and proportionality.
  • Deparvine filed an initial postconviction motion under Rule 3.851; an evidentiary hearing was held; the circuit court denied relief on numerous claims.
  • The postconviction court addressed twenty-one ineffective-assistance claims, several constitutional challenges to Florida’s capital sentencing scheme, and newly discovered evidence arguments.
  • Deparvine also filed a habeas corpus petition asserting ineffective assistance of appellate counsel; the Court denied relief on all claims.
  • The Court concludes that the postconviction court’s denials were correct and denies habeas relief.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
IAC claim: failure to call Gibson Gibson’s credibility would have aided innocence Counsel reasonably declined due to impeachment risk Claim not proven; strategic decision reasonable
IAC claim: failure to call Dacosta Dacosta testimony could undermine State theory Testimony would be confusing or unhelpful No deficient performance or prejudice
IAC claim: failure to move for judgment of acquittal / indictment theory Counsel should challenge indictment scope and vehicle identity Arguments were raised or rejected on direct appeal; no prejudice No deficient performance; evidence supported conviction
IAC claims re Lanier, Ferris, and related impeachment Counsel failed to adequately impeach key witnesses Counsel impeached effectively; strategic choices were reasonable No reversible error; claims fail
Constitutional challenges to Florida’s capital sentencing (Ring/Apprendi, proportionality, etc.) Ring/Apprendi errors and proportionality void death sentences Claims procedurally barred or meritless; prior felonies sustain verdict Claims are procedurally barred or meritless; sentences affirmed

Key Cases Cited

  • Strickland v. Washington, 466 U.S. 668 (Sup. Ct. 1984) (two-prong ineffective assistance standard; strong presumption of reasonableness)
  • Simmons v. State, 105 So.3d 475 (Fla. 2012) (Strickland mixed standard; guidance on postconviction review)
  • Pardo v. State, 108 So.3d 558 (Fla. 2012) (Eighth Amendment lethal injection framework; no new evidentiary hearing required)
  • Troy v. State, 57 So.3d 828 (Fla. 2011) (procedural bar and merits analysis for Bar rule and Caldwell-related claims)
Read the full case

Case Details

Case Name: William James Deparvine v. State of Florida
Court Name: Supreme Court of Florida
Date Published: Apr 24, 2014
Citation: 146 So. 3d 1071
Docket Number: SC12-407, SC12-2124
Court Abbreviation: Fla.