Reaves v. State

Summary

The Supreme Court of Florida reviews the summary denial of William Reaves's motion for postconviction relief under Florida Rule of Criminal Procedure 3.850. The court remands for an evidentiary hearing on claims that trial counsel was ineffective for failing to present a voluntary intoxication defense and related claims, while affirming the denial of relief on the remaining claims. The court also addresses alleged jury misconduct, Brady violations, public-records access, penalty-phase ineffectiveness, and cumulative error.

Holdings

1. A postconviction defendant is entitled to an evidentiary hearing on an ineffective-assistance claim when the claim is legally sufficient and the record does not conclusively refute it. Reaves's allegation that counsel failed to present a voluntary-intoxication defense met that standard.
2. Voluntary intoxication is a defense distinct from insanity and may be available to negate specific intent even when the defendant was capable of distinguishing right from wrong.
3. Claims that counsel inadequately questioned jurors, failed to cross-examine witnesses, conceded guilt, or failed to object to drug-use and other-bad-acts evidence were properly denied when they were deficiently pleaded, speculative, or unsupported by a showing of deficient performance and prejudice.
4. Reaves was not entitled to relief on his penalty-phase ineffective-assistance claims because the proposed mitigation was cumulative or insufficient to establish a reasonable probability that the balance of aggravating and mitigating circumstances would have changed.
5. The trial court properly denied an evidentiary hearing on Reaves's Brady claim because the motion did not allege facts showing that the withheld materials were favorable, suppressed by the State, and prejudicial.
6. A postconviction movant waives a public-records claim by failing to pursue the issue in the trial court.
7. Juror interviews are not permitted based solely on allegations concerning a juror's premature discussion of guilt or misunderstanding of jury instructions; an overt prejudicial act, external influence, or express agreement to disregard the law must be alleged.
8. A claim that a prisoner is insane for purposes of execution is premature until the Governor has conducted the proceedings required by Florida law.

Questions Presented

1. Whether Reaves was entitled to an evidentiary hearing on his claim that trial counsel was ineffective for failing to investigate and present a voluntary-intoxication defense.
2. Whether the remaining guilt-phase and penalty-phase ineffective-assistance claims were legally sufficient or refuted by the record.
3. Whether Reaves adequately pleaded a Brady violation concerning allegedly withheld materials.
4. Whether Reaves waived his public-records claim by failing to pursue it in the trial court.
5. Whether Reaves was entitled to interview jurors based on an allegation that one juror discussed his guilt before deliberations.
6. Whether Reaves's claim that he was insane for purposes of execution was premature.
7. Whether cumulative error required postconviction relief.

Disposition

reversed_and_remanded