Hector Sanchez-Torres v. State of Florida

Summary

The court affirmed the summary denial of Sanchez-Torres’s successive postconviction motion seeking to vacate his death sentence based on information concerning his codefendant. It held that relative-culpability analysis does not apply when the codefendant was legally ineligible for the death penalty and that the purported mitigation was immaterial because the sentencing court expressly did not rely on a triggerman finding. The court did not decide whether comparative proportionality review would otherwise bar the claim.