Carter v. State

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Questions Presented

1. Whether section 775.051, Florida Statutes (2002), which abolished voluntary intoxication as a defense, violated due process or equal protection.
2. Whether competent, substantial evidence supported Carter's three first-degree murder convictions.
3. Whether the trial court properly found the burglary and cold, calculated, and premeditated aggravating circumstances.
4. Whether the trial court abused its discretion in assigning great weight to the burglary and prior violent felony aggravators.
5. Whether the sentencing order sufficiently stated the trial court's consideration of aggravation, mitigation, and the jury's life recommendation for Smith.
6. Whether the State was bound by its promise to Mexican officials not to seek the death penalty.
7. Whether Carter's death sentences violated Ring v. Arizona.
8. Whether the standard penalty-phase jury instructions improperly diminished the jury's sense of responsibility.
9. Whether the death sentences were proportionate.

Holdings

1. Section 775.051, Florida Statutes (2002), which bars voluntary intoxication as a defense and bars its use to show lack of specific intent or insanity subject to the statutory prescription exception, is constitutional under due process and equal protection principles.
2. Competent, substantial evidence supported Carter's convictions for three first-degree murders.
3. The burglary aggravator was properly applied because the 2001 amendment to Florida's burglary statute clarified, rather than impermissibly broadened, the burglary definition, and competent, substantial evidence showed that Carter entered or remained in Reed's home with the intent to commit a forcible felony.
4. Competent, substantial evidence supported the finding that the murders of Reed and Pafford were cold, calculated, and premeditated without any pretense of moral or legal justification.
5. The trial court did not abuse its discretion by assigning great weight to the burglary and prior violent felony aggravators.
6. The sentencing order was sufficiently clear and complied with section 921.141(3) because it contained specific written findings concerning aggravation, mitigation, and the weight assigned to each factor.
7. The State was not bound by its promise to forego the death penalty because the condition of the proposed bargain was not fulfilled and judicial estoppel did not apply.
8. Carter's death sentences did not violate Ring because the prior violent felony aggravator was based on his unanimous jury convictions for the contemporaneous murders.
9. The standard penalty-phase jury instructions did not improperly diminish the jury's sense of responsibility for sentencing.
10. Carter's death sentences were proportionate to the murders of Reed and Pafford.

Key quotations

Factual background

Carter had previously dated Elizabeth Reed and became aware that Reed was seeing Glenn Pafford. After observing Pafford's truck at Reed's home, Carter drove there in the predawn hours carrying a loaded rifle. Following a confrontation inside the home, the rifle discharged and killed Reed's daughter Courtney Smith; Carter then intentionally shot Reed and Pafford multiple times in the head before fleeing. Carter escaped to Mexico and later worked under aliases in the United States until his arrest in Kentucky.

Procedural history

A grand jury indicted Carter on three counts of first-degree murder with a firearm. After trial, the jury found him guilty of both premeditated and felony murder for each killing and recommended death for two victims and life imprisonment for the third. The trial court imposed life imprisonment for the murder of Smith and death sentences for the murders of Pafford and Reed. The Supreme Court of Florida affirmed the convictions and sentences on direct appeal.