Derrick Tyrone Smith, Appellant v. State of Florida, Appellee

Summary

The Florida Supreme Court affirmed the circuit court’s denial of Derrick Tyrone Smith’s successive post‑conviction relief motions, finding that the post‑conviction court correctly applied the cumulative materiality analysis required by Kyles and that Smith’s newly discovered evidence claim failed the Jones test. The Court held that the undisclosed evidence, taken together, did not undermine confidence in the verdict. Justice Pariente dissented, arguing that the cumulative errors warrant a new trial.