Derral Wayne Hodgkins, Appellant v. State of Florida, Appellee

Summary

The Court held that the circumstantial evidence was legally insufficient to prove that Hodgkins killed Lodge, even though it showed that his DNA was found under Lodge’s fingernails and that he had repeatedly lied about their recent contacts. The evidence did not establish when or how the DNA was deposited, did not connect Hodgkins to the crime scene or murder weapon, and remained consistent with the reasonable hypothesis that someone else killed Lodge. The Court reversed and vacated the conviction and death sentence and remanded for entry of a judgment of acquittal. Justice Canady, dissenting, would have deferred to the jury’s reasonable inferences from the DNA evidence, Lodge’s cleaning practices, and Hodgkins’ changing statements; Chief Justice Labarga, concurring, addressed the required individualized inquiry before shackling a defendant during the penalty phase.