Wright v. State

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Questions Presented

1. Whether Wright's second postconviction motion was procedurally barred insofar as it sought reconsideration of claims raised or that could have been raised in the first postconviction proceeding.
2. Whether alleged undisclosed police information constituted material Brady evidence requiring a new trial.
3. Whether documents obtained through later public-records requests constituted newly discovered evidence of innocence.
4. Whether the special-deputy status of defense counsel or his investigator created an actual conflict of interest or ineffective assistance of counsel.
5. Whether the trial judge's alleged special-deputy status required disqualification or otherwise denied Wright due process.
6. Whether the trial court improperly relied on facts from another case to reject Wright's claim concerning preparation of sentencing orders.
7. Whether alleged delay in ruling on a postconviction motion violated due process.
8. Whether a claim that the Supreme Court of Florida failed to conduct a harmless-error analysis belonged in a Rule 3.850 proceeding.
9. Whether appellate counsel was ineffective for failing to raise various unpreserved or previously litigated issues.
10. Whether Florida's capital sentencing scheme violated Apprendi v. New Jersey and Ring v. Arizona.
11. Whether the striking of the cold, calculated, and premeditated aggravating circumstance required resentencing under Sochor v. Florida.

Holdings

1. A defendant may not relitigate in a successive postconviction motion claims that were raised or could have been raised in an earlier postconviction proceeding absent a showing that the grounds were previously unknown and could not have been known through due diligence.
2. To establish a Brady violation, a defendant must show that the evidence was favorable, was suppressed by the State, and resulted in prejudice; speculative or merely potentially useful information is not constitutionally material.
3. Evidence qualifies as newly discovered only if it was unknown to the court, party, and counsel at trial and could not have been discovered through due diligence; if so, it must also be likely to produce an acquittal on retrial.
4. A claim that defense counsel had a conflict of interest requires proof that counsel actively represented conflicting interests and that an actual conflict adversely affected counsel's performance; an honorary or inactive special-deputy status, without evidence of divided loyalty or impact on representation, does not establish a conflict.
5. A defendant seeking judicial disqualification must allege well-founded facts showing undue bias, prejudice, or sympathy; the mere possession of a special-deputy card, without evidence of partiality or effect on rulings, does not require disqualification.
6. Postconviction relief cannot be based on factual findings or actions from another defendant's case or on speculation concerning what occurred in that case.
7. Appellate counsel is not ineffective for failing to raise issues that were unpreserved at trial, were previously litigated, or were conclusory and legally insufficient.
8. A trial court substantially complies with Florida Rule of Criminal Procedure 3.410 when, after clarifying a jury's request to rehear testimony, it declines to reread the testimony after the parties object and instructs the jury in open court and in the defendant's presence to rely on its collective memory.
9. Wright's constitutional challenge to Florida's capital sentencing scheme under Apprendi and Ring was rejected; the court relied on its contemporaneous decisions upholding the scheme and noted that the jury found burglary and sexual battery beyond a reasonable doubt.
10. When one aggravating circumstance is struck and no valid mitigating circumstances exist, resentencing is not necessarily required if there is no likelihood of a different sentence; under those circumstances, reliance on the unsupported aggravator may be harmless.

Key quotations

Factual background

A woman was murdered in her home on February 6, 1983, after being raped and stabbed. The State's principal evidence included testimony that Wright confessed to the murder, testimony linking Wright to an earlier burglary of the victim's home, and a fingerprint identified as Wright's on a portable stove in the victim's bedroom. Wright denied involvement and presented an alibi-related defense, but the jury convicted him and recommended death.

Procedural history

Wright was convicted in 1983 of first-degree murder, sexual battery, burglary of a dwelling, and grand theft and was sentenced to death. The Supreme Court of Florida affirmed the convictions and sentence on direct appeal. After an evidentiary hearing, the trial court denied Wright's first postconviction motion; the Supreme Court affirmed in part and remanded for a hearing on a conflict-of-interest claim concerning defense counsel's special-deputy status. Following additional hearings and amendments, the trial court denied Wright's second postconviction motion, leading to this appeal and habeas petition.