Leonardo Franqui v. State of Florida

Summary

The court affirmed the denial of Franqui’s successive postconviction claims alleging intellectual disability and sentencing error. It held that competent substantial evidence supported the circuit court’s findings on all three intellectual-disability prongs, that Franqui’s challenge to the clear-and-convincing burden was unpreserved, and that the jury’s unanimous aggravating-factor findings defeated his sentencing claims. The court also held that intellectual disability is determined by a judge rather than a jury under Florida law.