Jones v. State; Jones v. Crosby

Summary

The Supreme Court of Florida affirmed the denial of Victor Tony Jones's motion for postconviction relief under Florida Rule of Criminal Procedure 3.850 and denied his petition for writ of habeas corpus. The court rejected claims of ineffective assistance concerning voluntary intoxication and penalty-phase mitigation, and also rejected his constitutional challenge under Ring v. Arizona and Apprendi v. New Jersey.

Holdings

1. Trial counsel was not constitutionally ineffective for declining to pursue a voluntary-intoxication defense because the decision was a reasonable strategic choice, the defense was inconsistent with Jones's assertion of innocence, and Jones failed to establish evidence of intoxication sufficient to impair his ability to form specific intent.
2. Trial counsel was not constitutionally ineffective in investigating or presenting mitigating evidence because counsel conducted a reasonable investigation, made reasonable strategic choices concerning which witnesses and experts to present, and Jones failed to show that additional investigation or testimony would have produced a different penalty-phase result.
3. Jones was not entitled to habeas relief on his ineffective-assistance-of-appellate-counsel claims because the claims were procedurally barred or lacked merit.
4. Jones's challenge to Florida's capital-sentencing scheme under Ring and Apprendi was rejected under Bottoson v. Moore; the prior-violent-felony aggravator also falls within the prior-conviction exception and need not be found by the jury.

Questions Presented

1. Whether trial counsel provided ineffective assistance by failing to investigate and present a voluntary-intoxication defense.
2. Whether trial counsel provided ineffective assistance by failing adequately to investigate and present family and mental-health mitigating evidence during the penalty phase.
3. Whether Jones's remaining claims of ineffective assistance of trial counsel and other postconviction claims warranted relief.
4. Whether appellate counsel was ineffective for failing to raise specified issues on direct appeal.
5. Whether Florida's capital-sentencing scheme was unconstitutional under Ring v. Arizona and Apprendi v. New Jersey.

Disposition

affirmed