Supreme Court of Florida

Joel Lebron v. State of Florida

December 21, 2017

Summary

The court affirmed Lebron's convictions, holding that his post-warning confession was admissible because officers did not deliberately employ a two-step interrogation strategy and Lebron knowingly and voluntarily waived his rights. The court also upheld the rulings rejecting his mistrial claims, excluding QEEG evidence, and sustaining the murder conviction as supported by competent and substantial evidence. It vacated the death sentence because the jury's nine-to-three recommendation did not establish a unanimous finding that aggravating circumstances outweighed mitigation, and remanded for a new penalty phase.