Supreme Court of Florida

Michael Lee Robinson v. State of Florida

December 20, 2018

Summary

The court affirmed the denial of Robinson's successive motion for postconviction relief. It held that his death sentence became final before the relevant constitutional decisions and therefore those decisions did not apply retroactively; alternatively, his challenge was procedurally barred and his valid waiver of a penalty-phase jury foreclosed relief. The court concluded that a later change in law did not invalidate the prior waiver.