David Kelsey Sparre v. State of Florida

Summary

The court affirmed the summary denial of Sparre’s second successive postconviction motion because his claims were untimely, procedurally barred, and meritless. The newly discovered evidence exception did not apply because the study relied on information available years earlier, and the constitutional claims failed because the Sixth Amendment concerns the representativeness of the jury pool rather than the petit jury, while the Eighth Amendment and Florida Constitution did not establish the asserted right. The court also concluded that any error in failing to hold the required case management conference was harmless.