Howard Steven Ault, Appellant v. State of Florida, Appellee

Summary

The court affirmed the denial of postconviction relief on Ault’s ineffective-assistance claim concerning guilt-phase counsel because the detailed confession conclusively defeated any reasonable-probability showing of prejudice. The court held that the penalty-phase jury recommendations did not establish harmlessness beyond a reasonable doubt because they were nonunanimous and the jury made no unanimous findings on the facts necessary for death, so it vacated the death sentences and remanded for a new penalty phase. POLSTON, J., concurring in part and dissenting in part, would have joined the majority except for vacating the death sentences under the applicable jury-unanimity rule.