Ballard v. State

Summary

The Supreme Court of Florida affirmed Roy Phillip Ballard’s first-degree murder conviction and upheld the admission of collateral-crime evidence concerning his sexual relationship with the victim’s minor daughter. The court also upheld the cold, calculated, and premeditated aggravator but held that the death sentence was disproportionate in light of the mitigation, vacating it and remanding for imposition of life imprisonment without the possibility of parole. A dissent would have affirmed the death sentence.

Holdings

1. The trial court did not abuse its discretion by admitting evidence of Ballard's sexual relationship with Suny because the evidence was relevant to establish motive and was inextricably intertwined with the events surrounding Autumn's murder.
2. Competent, substantial evidence supported the trial court's finding of the cold, calculated, and premeditated aggravator.
3. The evidence was sufficient to sustain Ballard's first-degree murder conviction.
4. The death sentence was disproportionate and had to be vacated and reduced to life imprisonment without the possibility of parole.
5. Ballard's constitutional challenge under Ring v. Arizona was moot because the death sentence was being vacated and replaced with life imprisonment.

Questions Presented

1. Whether the trial court improperly admitted collateral-crime evidence concerning Ballard's sexual relationship with Suny Houghtling.
2. Whether competent, substantial evidence supported the cold, calculated, and premeditated aggravating circumstance.
3. Whether the death sentence was proportionate in light of the aggravating and mitigating circumstances.
4. Whether Florida's death-penalty statute was unconstitutional under Ring v. Arizona.

Disposition

reversed_and_remanded