Buenoano v. State

527 So. 2d 194 (Fla. 1988) · Supreme Court of Florida · June 23, 1988 · No. No. 68091

Summary

The Supreme Court of Florida affirmed Buenoano's conviction for first-degree murder and her death sentence for the arsenic poisoning death of her husband, James E. Goodyear. The court held that evidence concerning the poisoning death of another associate and the attempted poisoning of her fiancé was admissible under Florida's Williams rule, and that the State established the corpus delicti through independent circumstantial and medical evidence. The court also upheld the aggravating circumstances supporting the death penalty, including pecuniary gain and that the murder was heinous, atrocious, or cruel.

Holdings

  1. Collateral-crimes evidence was admissible because the poisoning offenses shared a uniquely similar modus operandi and was relevant to material issues including motive, opportunity, identity, intent, absence of mistake, and common plan or scheme.
  2. The State was not required to prove the corpus delicti beyond a reasonable doubt before admitting a confession or collateral-crimes evidence; circumstantial evidence establishing a prima facie showing was sufficient.
  3. The trial court properly denied a mistrial because the unsolicited statement that Buenoano set fire to her house was not sufficiently prejudicial to deny a fair trial, particularly after the court sustained the objection and gave a curative instruction.
  4. Testimony concerning the events underlying Buenoano's prior felony conviction was admissible during the penalty phase because legally obtained probative hearsay could be considered when the defendant had a fair opportunity to rebut it; any error was harmless.
  5. The evidence supported the findings that the murder was committed for pecuniary gain and was heinous, atrocious, or cruel, in addition to the two unchallenged aggravating circumstances.

Questions Presented

  1. Whether evidence concerning the arsenic poisoning of Bobby Joe Morris and the attempted poisoning of John Gentry was admissible under Florida's Williams rule.
  2. Whether the State established the corpus delicti of homicide independently of Buenoano's confessions and the collateral-crimes evidence.
  3. Whether a witness's unsolicited statement that Buenoano set fire to her own house required a mistrial.
  4. Whether testimony concerning Buenoano's prior murder conviction was admissible during the penalty phase and, if erroneous, whether the error was harmless.
  5. Whether the evidence supported the aggravating circumstances that the murder was committed for pecuniary gain and in a heinous, atrocious, or cruel manner.
  6. Whether the conviction and death sentence were supported by the record.

Disposition

affirmed

Cases Cited (10)

  • Williams v. State, 110 So. 2d 654 (Fla.), cert. denied, 361 U.S. 847, 80 S. Ct. 102, 4 L. Ed. 2d 86 (1959)(followed)
  • Chandler v. State, 442 So. 2d 171 (Fla. 1983)(followed)
  • Kight v. State, 512 So. 2d 922, 928 (Fla. 1987)(followed)
  • Drake v. State, 400 So. 2d 1217, 1219 (Fla. 1981)(followed)
  • Bassett v. State, 449 So. 2d 803 (Fla. 1984)(followed)
  • State v. Allen, 335 So. 2d 823 (Fla. 1976)(followed)
  • Delap v. State, 440 So. 2d 1242 (Fla. 1983), cert. denied, 467 U.S. 1264, 104 S. Ct. 3559, 82 L. Ed. 2d 860 (1984)(followed)
  • Ferguson v. State, 417 So. 2d 631 (Fla. 1982)(followed)
  • Elledge v. State, 346 So. 2d 998 (Fla. 1977)(followed)
  • State v. Dixon, 283 So. 2d 1, 9 (Fla. 1973), cert. denied, 416 U.S. 943, 94 S. Ct. 1950, 40 L. Ed. 2d 295 (1974)(followed)

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