Supreme Court of Florida
Johnny Mack Sketo Calhoun v. State of Florida
October 31, 2013138 So. 3d 349
Summary
The court affirmed Calhoun’s convictions for first-degree murder and kidnapping and his death sentence, although it struck the avoid-arrest aggravating factor. It held that any error concerning exclusion of portions of Calhoun’s police interview was unpreserved and harmless beyond a reasonable doubt, and that competent substantial evidence supported the CCP aggravator, the convictions, and the proportionality of the death sentence. Justice Lewis, concurring in part and dissenting in part, would have upheld the avoid-arrest aggravator because the evidence supported a finding that avoiding arrest was the dominant motive for the killing.