Supreme Court of Florida
Richard Knight, Appellant v. State of Florida, Appellee; Richard Knight, Petitioner, v. Julie L. Jones
January 31, 2017225 So. 3d 661
Summary
The court affirmed the denial of Knight’s postconviction motion and denied habeas relief. It rejected his ineffective-assistance, Brady, procedural, lethal-injection, and appellate-counsel claims, concluding that the record supported the lower court’s factual findings and that Knight failed to establish deficient performance, prejudice, suppression, materiality, or a preserved appellate issue. Although the court recognized that Knight’s sentencing procedure violated the constitutional requirement that the jury find the facts necessary for death, it held the violation harmless beyond a reasonable doubt because the jury unanimously recommended death and the aggravating and mitigating evidence was presented under substantially adequate instructions. Justice Quince and Senior Justice Perry, concurring in part and dissenting in part, would have granted sentencing relief, with Quince favoring a new penalty phase and Perry favoring life imprisonment.