White v. State

Summary

The Supreme Court of Florida affirmed William Melvin White’s death sentence following resentencing for the first-degree murder of Gracie Mae Crawford. The court rejected claims concerning limits on cross-examination and reverse Williams rule evidence, the witness-elimination aggravator, the extreme-duress or substantial-domination mitigator, proportionality, and the effect of prolonged incarceration on death row.

Holdings

1. The trial court did not abuse its discretion by allowing the defense to establish the witness's felony convictions, the type of felony, his plea and cooperation agreements, and his lifestyle, while excluding the detailed facts underlying his unrelated Maryland murder conviction.
2. The underlying facts of the witness's Maryland murder conviction were properly excluded because they lacked the close factual similarity and logical relevance necessary for reverse Williams rule evidence.
3. The trial court properly found that White killed Crawford to disrupt or hinder enforcement of laws by eliminating her as a witness to the preceding beating.
4. The trial court properly rejected the statutory mitigating circumstance that White acted under extreme duress or substantial domination of another.
5. White's death sentence was not disproportionate compared with the sentences of his codefendants or with other capital cases.
6. The claim that execution after more than twenty-two years on death row would constitute cruel and unusual punishment was summarily rejected as previously decided.

Questions Presented

1. Whether the trial court improperly limited cross-examination of the State's key witness concerning the underlying facts of the witness's subsequent Maryland murder conviction.
2. Whether the underlying facts of the witness's subsequent Maryland murder conviction were admissible as reverse Williams rule evidence.
3. Whether competent, substantial evidence supported the aggravating circumstance that the murder was committed to disrupt or hinder enforcement of laws.
4. Whether competent, substantial evidence supported rejection of the statutory mitigator that White acted under extreme duress or substantial domination of another.
5. Whether White's death sentence was disproportionate in light of the culpability and sentences of his codefendants and other capital cases.
6. Whether execution after more than twenty-two years on death row would constitute cruel and unusual punishment.

Disposition

affirmed