Reynaldo Figueroa-Sanabria v. State of Florida

Summary

The court affirmed Figueroa-Sanabria’s first-degree murder convictions, rejecting his challenges to the denial of substitute counsel, the admission of historical cell-site location information, and the sufficiency of the evidence. It held that any error in admitting the historical cell-site information was harmless because the remaining evidence was substantial and independently inculpatory. The court set aside both death sentences and remanded for a new penalty phase because the trial court improperly conditioned continued representation on presenting mitigation, rendering Figueroa-Sanabria’s waiver of counsel invalid and fundamentally erroneous.