David Kelsey Sparre, Appellant v. State of Florida, Appellee

Summary

The court affirmed Sparre’s first-degree murder conviction and death sentence after rejecting his challenges concerning mitigation, the governing waiver framework, the constitutional requirements for capital sentencing, sufficiency of the evidence, and proportionality. The court held that the record did not show an abuse of discretion in declining to call mitigation witnesses, that any such error would be harmless beyond a reasonable doubt, and that the conviction and sentence were supported by competent, substantial evidence. Justice Pariente, concurring in part and dissenting in part, would have vacated the death sentence because the trial court failed to investigate substantial mental-health and background mitigation and would have required special counsel whenever a defendant waives mitigation.