Tiffany Ann Cole, Appellant v. State of Florida, Appellee

Summary

The court affirmed the denial of Cole's guilt-phase postconviction claims, holding that counsel was not ineffective for failing to challenge the search warrant, arrest, or post-arrest statements and that counsel reasonably investigated and rejected a duress-centered defense. Because Cole's death sentences followed a nonunanimous jury recommendation under Florida's former capital sentencing scheme, the court held that the Hurst error was not harmless and granted a new penalty phase. Justice Pariente concurred in the Hurst relief, Justice Lawson specially concurred, and Justice Canady, joined by Justice Polston, would have affirmed the denial of all relief.