Supreme Court of Florida

Lucious Boyd, Appellant v. State of Florida, Appellee; Lucious Boyd, Petitioner, v. Julie L. Jones

December 17, 2015200 So. 3d 685

Summary

The court affirmed the denial of Boyd’s postconviction motion and denied his habeas petition. It held that the service of a convicted felon or a juror with a prior misdemeanor encounter does not automatically require a new trial absent legally sufficient evidence of actual bias, and it rejected Boyd’s ineffective-assistance claims because counsel’s challenged decisions were reasonable or caused no prejudice. Justice Lewis, concurring in the result only, would have treated the improperly constituted jury as a structural defect requiring a new trial, while Justice Quince, dissenting, would have adopted a per se new-trial rule.