Hendrix v. State

Summary

The Supreme Court of Florida affirmed the denial of Robert Eugene Hendrix's motion for postconviction relief under Florida Rule of Criminal Procedure 3.850 and denied his petition for a writ of habeas corpus. The court rejected claims involving ineffective assistance of counsel, undisclosed information concerning a prosecution witness, shackling, mitigation evidence, and the heinous, atrocious, or cruel aggravator. The court concluded that Hendrix failed to establish deficient performance, prejudice, or a Brady violation.

Holdings

1. Hendrix failed to establish both deficient performance and resulting prejudice under Strickland; the postconviction court therefore properly denied his ineffective-assistance claims.
2. The State should have disclosed LaForce's prior cooperation with law enforcement as favorable impeachment evidence, but the nondisclosure did not prejudice Hendrix and therefore did not warrant relief.
3. Hendrix failed to establish ineffective assistance based on counsel's failure to object to shackling because the restraints were justified by security concerns, were not visible or audible to the jury, and caused no demonstrated prejudice.
4. Appellate counsel was not ineffective for failing to raise the shackling issue on direct appeal because the claim was unpreserved and depended on facts outside the direct-appeal record.
5. Hendrix's claim concerning newly discovered evidence and judicial impartiality was procedurally barred because the specific legal argument was not presented to the postconviction court.

Questions Presented

1. Whether the postconviction court erred in denying Hendrix's ineffective-assistance claims concerning trial counsel's handling of relevance evidence, witness impeachment, alleged judicial-prosecutorial connections, penalty-phase mitigation, the heinous-atrocious-or-cruel aggravator, and shackling.
2. Whether the State violated Brady v. Maryland by failing to disclose LaForce's prior cooperation as a confidential informant or cooperating defendant.
3. Whether Hendrix was denied a fair trial or ineffective assistance because he was shackled without the required findings and because the restraints allegedly could have been perceived by the jury.
4. Whether appellate counsel was ineffective for failing to raise the shackling issue on direct appeal.
5. Whether Hendrix's first postconviction claim concerning newly discovered evidence and judicial impartiality was preserved for review.

Disposition

affirmed