Ronald Knight v. State of Florida; Ronald Knight v. Julie L. Jones

Summary

The Supreme Court of Florida consolidated Ronald Knight’s appeal from the denial of his postconviction motion and his petition for habeas corpus. The court affirmed the denial of postconviction relief and denied habeas relief, rejecting claims concerning ineffective assistance of counsel, jury and counsel waivers, speedy trial and double jeopardy, mitigation evidence, and lethal-injection procedures.

Holdings

1. Knight failed to establish deficient performance because the additional mitigation evidence either did not materially alter the existing expert opinion, was of limited value, or was unavailable or unwilling to testify at trial. Relief was therefore properly denied without reaching prejudice.
2. Knight's counsel was not ineffective for failing to seek dismissal on double-jeopardy grounds because jeopardy had not attached in the earlier prosecution; no jury had been impaneled and sworn to hear the case.
3. Knight's counsel was not ineffective for failing to seek discharge on speedy-trial grounds because defense continuances before expiration of the speedy-trial period waived the speedy-trial right, and the failure to commence trial was also attributable to Knight's witness intimidation.
4. Knight's claim of trial-court error based on an alleged Richardson violation was procedurally barred in postconviction proceedings, and his ineffective-assistance claim failed for lack of prejudice because the allegedly withheld materials added no meaningful impeachment or exculpatory value.
5. The postconviction court did not abuse its discretion by reappointing CCRC-South and offering Knight the choice of continuing with counsel or proceeding pro se; Knight was not entitled to counsel of his choice and had not unequivocally elected self-representation.
6. The claims concerning Knight's waiver of guilt-phase counsel and his jury waivers were procedurally barred or meritless. The record established that the jury waivers were knowing, intelligent, and voluntary, so appellate counsel was not ineffective for failing to raise them.
7. Knight's challenge to Florida's lethal-injection procedures was summarily rejected because the Supreme Court of Florida had repeatedly rejected materially similar claims.
8. Knight failed to establish ineffective assistance of appellate counsel because his allegations concerning missing transcripts, records, and impeachment materials were conclusory and did not demonstrate deficient performance or prejudice.

Questions Presented

1. Whether penalty-phase counsel was ineffective for failing to investigate and present additional mitigation evidence.
2. Whether trial counsel was ineffective for failing to seek discharge or dismissal based on double jeopardy or speedy-trial violations arising from an earlier prosecution that ended in a nolle prosequi.
3. Whether counsel was ineffective for failing to raise an alleged Richardson discovery violation.
4. Whether the reappointment of Capital Collateral Regional Counsel—Southern Region over Knight's objection violated his right to self-representation or required appointment of substitute counsel.
5. Whether Knight's waivers of guilt-phase counsel and guilt- and penalty-phase juries were knowing, intelligent, and voluntary.
6. Whether Florida's lethal-injection procedures were unconstitutional.
7. Whether appellate counsel was ineffective for failing to challenge Knight's jury waivers or the completeness of the appellate record.

Disposition

affirmed