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

Summary

The court affirmed Sparre’s first-degree murder conviction and death sentence, rejecting his challenges concerning the trial court’s handling of waived mitigation, adherence to controlling precedent, the constitutionality of Florida’s capital-sentencing scheme, evidentiary sufficiency, and proportionality. It held that the presentence investigation report and record were sufficient, any possible error regarding additional mitigation was harmless beyond a reasonable doubt, and the aggravating circumstances outweighed the mitigating evidence. Justice Pariente, concurring in part and dissenting in part, would have affirmed the conviction but ordered a new penalty phase because the trial court failed to investigate substantial proffered mental-health and background mitigation.