Mann v. State

Summary

The Florida Supreme Court affirmed the denial of Larry Eugene Mann’s successive postconviction motion and public-records requests and denied his petition for a writ of habeas corpus. The court rejected challenges to Florida’s non-unanimous death-sentence recommendations and the Governor’s death-warrant selection process, found the requested records unrelated to a colorable claim, and held that Martinez v. Ryan did not provide relief in state court. The court also concluded that Mann’s underlying ineffective-assistance claim lacked merit because mitigation evidence had been presented.

Holdings

1. A successive Rule 3.851 motion may be summarily denied without an evidentiary hearing when the record conclusively demonstrates that the movant is entitled to no relief; purely legal claims previously rejected by the court do not require an evidentiary hearing.
2. Florida's capital-sentencing scheme allowing a death sentence based on a simple-majority jury recommendation is not unconstitutional under the court's established precedent.
3. The claim that the Governor's discretion to select inmates for execution and sign death warrants is unconstitutional was properly denied as untimely and meritless.
4. A capital defendant is not entitled to additional public records unless the request satisfies Rule 3.852 and the defendant demonstrates that the records relate to a colorable postconviction claim or may reasonably lead to admissible evidence; the court properly denied Mann's requests.
5. Martinez v. Ryan does not provide relief in Florida state postconviction proceedings or authorize Mann to overcome the procedural bar to his ineffective-assistance claim.
6. Mann's habeas petition was procedurally barred because it merely restated a claim that could have been, should have been, or was raised on appeal or in a Rule 3.850 motion.

Questions Presented

1. Whether Florida's statutory scheme permitting a death sentence based on a non-unanimous jury recommendation violates the Constitution or evolving standards of decency.
2. Whether the Governor's discretion to select inmates for execution and sign death warrants is unconstitutional.
3. Whether Mann was entitled to additional public records under Florida Rule of Criminal Procedure 3.852 and chapter 119, Florida Statutes.
4. Whether Martinez v. Ryan permits Mann to overcome a procedural bar to an ineffective-assistance claim in state postconviction proceedings.
5. Whether Mann was entitled to habeas relief on his challenge to Florida's non-unanimous capital-jury recommendation procedure.

Disposition

affirmed