Howell v. State

Summary

The Supreme Court of Florida affirmed the denial of Paul Augustus Howell's motion for postconviction relief under Florida Rule of Criminal Procedure 3.850. The court held that trial counsel's decision not to present evidence that the victim violated Florida Highway Patrol search procedures was a reasonable strategic decision and did not establish ineffective assistance under Strickland. The court also rejected Howell's constitutional challenge to Florida's capital sentencing scheme under Ring v. Arizona and Apprendi v. New Jersey.

Holdings

1. Trial counsel was not constitutionally ineffective for declining to present the alleged Florida Highway Patrol policy violation as an intervening-cause defense.
2. Trial counsel was not constitutionally ineffective for declining to use the alleged policy violation as nonstatutory mitigating evidence.
3. Howell was not entitled to postconviction relief based on Ring or Apprendi.

Questions Presented

1. Whether trial counsel rendered ineffective assistance by failing to present evidence that Trooper Fulford violated Florida Highway Patrol procedures when opening the bomb-containing package, either as an intervening-cause defense during the guilt phase or as nonstatutory mitigation during the penalty phase.
2. Whether Florida's capital-sentencing scheme was unconstitutional under Ring v. Arizona and Apprendi v. New Jersey.

Disposition

affirmed