Tiffany Ann Cole, Appellant v. State of Florida, Appellee

Summary

The court affirmed Cole's convictions for two first-degree murders, two kidnappings, and two robberies, and affirmed both death sentences. It held that any improper trial comment was not fundamental error, the challenged photographs were properly admitted, the evidence was sufficient, and the penalty-phase errors did not warrant relief. The court struck the HAC aggravator because Cole neither directed nor knew that the victims would be buried alive, but found that error harmless in light of six remaining aggravators and minimal mitigation. Canady, J., concurring in the result, would have upheld the HAC finding or alternatively deemed any error harmless and questioned the governing precedent.