Lightbourne v. State

Summary

The Supreme Court of Florida affirmed the denial of Ian Deco Lightbourne's successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.850. The court rejected claims involving Brady, Giglio, and Henry violations, concluding that the jailhouse informants were not acting as state agents, that the alleged recantations and related evidence were not credible, and that no material prejudice was shown. The court also held that the newly discovered evidence would not probably result in a life sentence or otherwise warrant relief.

Holdings

1. Lightbourne failed to establish a Brady violation because the evidence offered to show that the informants were solicited by the State or testified falsely was not credible, and the cumulative evidence did not establish that Chavers and Carson acted as state agents or were untruthful at trial.
2. Lightbourne failed to satisfy the newly discovered evidence standard because, considering all admissible newly discovered evidence cumulatively and weighing its credibility and materiality, the evidence would not probably produce a life sentence at a new penalty-phase proceeding.
3. The claim was procedurally barred because Lightbourne abandoned it by failing to seek rehearing when the court previously failed to address it.
4. Lightbourne was not entitled to relief on the conflict-of-interest claim, and the trial court did not err in denying collateral counsel's motion to withdraw.

Questions Presented

1. Whether the cumulative post-trial evidence established a Brady violation based on alleged suppression of evidence concerning jailhouse informants and alleged Giglio or Henry violations.
2. Whether the informants' recantations and related testimony constituted newly discovered evidence warranting a new penalty-phase proceeding.
3. Whether Lightbourne's claim concerning the prior representation of Larry Emanuel by an assistant state attorney was procedurally barred because Lightbourne failed to seek rehearing when the Florida Supreme Court previously did not address it.
4. Whether the trial court erred in denying collateral counsel's motion to withdraw based on an alleged conflict of interest.

Disposition

affirmed