Blackwood v. State; Blackwood v. McDonough

Summary

The Supreme Court of Florida reviews Lynford Blackwood’s postconviction claims arising from his first-degree murder conviction and death sentence. The court affirms the denial of guilt-phase ineffective-assistance claims, affirms the grant of a new penalty proceeding based on counsel’s inadequate investigation and presentation of mental-health mitigation, and denies habeas relief.

Holdings

1. The circuit court properly summarily denied Blackwood's guilt-phase ineffective-assistance claims because the racial-bias claim was procedurally barred and the remaining claims were facially insufficient, conclusively refuted by the record, or failed to establish deficient performance and prejudice.
2. Trial counsel provided ineffective assistance during the penalty phase by abandoning investigation and presentation of available statutory and nonstatutory mental-health mitigation after the expected expert became unavailable, and the resulting prejudice warranted a new penalty-phase proceeding.
3. Blackwood was not entitled to habeas relief because his Ring and Apprendi claims were procedurally barred and, independently, Ring was not retroactive to his case.

Questions Presented

1. Whether the circuit court properly summarily denied Blackwood's guilt-phase ineffective-assistance claims involving alleged racial bias, substance abuse, jury selection, cross-examination, and failure to object.
2. Whether trial counsel was constitutionally ineffective during the penalty phase by failing to meaningfully investigate, prepare, and present mental-health mitigation evidence.
3. Whether Blackwood was entitled to habeas relief under Ring v. Arizona or Apprendi v. New Jersey.

Disposition

affirmed