Richard Todd Robards, Appellant v. State of Florida, Appellee

Summary

The court affirmed the denial of relief on Robards's claim that guilt-phase counsel was ineffective for failing to challenge evidence concerning his offer to make a deal, holding that the communication was not a plea negotiation and that any error was not prejudicial. The court held that Robards was entitled to a new penalty phase because the jury did not make the unanimous factual findings required for a death sentence and the State could not prove the constitutional error harmless beyond a reasonable doubt. Justice Pariente, concurring, would also grant a new penalty phase based on counsel's inadequate investigation of substantial mental-health mitigation, while Justice Polston, concurring in part and dissenting in part, would not vacate the death sentences.