Tina Lasonya Brown v. State of Florida & Tina Lasonya Brown v. Mark S. Inch

Summary

The court affirmed the denial of Brown’s postconviction motion and denied her habeas petition. It held that although counsel was deficient in failing to present certain impeachment evidence and witnesses, Brown failed to establish a reasonable probability of a different guilt or sentencing outcome, and her newly discovered evidence did not satisfy the standard for a new trial or lesser sentence. The court also held that the unsubmitted jury finding concerning the kidnapping aggravator was harmless beyond a reasonable doubt and that appellate counsel was not ineffective for failing to raise prosecutorial-misconduct claims that did not constitute fundamental error.