Hodges v. State

Summary

The Supreme Court of Florida affirmed Willie James Hodges’s first-degree murder conviction and death sentence for the killing of Patricia Belanger. The court rejected challenges concerning the determination of intellectual disability, admission and use of collateral-crime evidence, waiver of a penalty-phase jury, and the constitutionality of the death sentence under Ring v. Arizona. The court also reviewed the sufficiency of the evidence and sentence proportionality.

Holdings

1. A capital defendant has no right under Ring or Atkins to have a jury determine whether he is mentally retarded for purposes of eligibility for execution.
2. The trial court's finding that Hodges failed to prove concurrent deficits in adaptive behavior was supported by competent, substantial evidence; therefore, Hodges was not entitled to relief from the death sentence on that ground.
3. The trial court did not abuse its discretion by permitting the State to argue from properly admitted collateral-crime evidence during rebuttal to the defense theory that Hodges was not the perpetrator.
4. The collateral-crime evidence did not impermissibly become a feature of the trial.
5. The trial court could reject Hodges's waiver of a penalty-phase jury and require an advisory jury recommendation.
6. Ring did not entitle Hodges to relief because the prior-violent-felony and under-sentence-of-imprisonment aggravators applied, and Florida was not required to obtain a unanimous jury sentencing recommendation.
7. The evidence was sufficient to support Hodges's first-degree murder conviction under both premeditated-murder and felony-murder theories.
8. Hodges's death sentence was proportionate and constitutionally permissible.

Questions Presented

1. Whether Hodges was entitled to have a jury determine his mental-retardation status as a bar to execution.
2. Whether competent, substantial evidence supported the trial court's finding that Hodges did not have concurrent deficits in adaptive behavior.
3. Whether the State could discuss collateral-crime evidence during rebuttal closing argument.
4. Whether the collateral-crime evidence impermissibly became a feature of the trial.
5. Whether the trial court erred by refusing to permit Hodges to waive the penalty-phase jury.
6. Whether Florida's capital-sentencing scheme violated Ring v. Arizona because of the prior-violent-felony aggravator or its allowance of a nonunanimous jury recommendation.
7. Whether sufficient evidence supported Hodges's first-degree murder conviction under theories of premeditated murder and felony murder.
8. Whether Hodges's death sentence was proportionate.

Disposition

affirmed