Summary
The Florida Supreme Court affirmed the denial of Richard Eugene Hamilton’s successive motion for postconviction relief and requests for additional public records. The court held that his claims, including a claim under Hurst v. Florida, were untimely under Florida Rule of Criminal Procedure 3.851 and that the trial court did not abuse its discretion in denying the records requests. Justice Pariente dissented, arguing that Hamilton should receive a new penalty phase based on Hurst and the jury’s nonunanimous death recommendation.
Topics
Practice areas
Questions Presented
- Whether Hamilton's successive postconviction motion was timely under Florida Rule of Criminal Procedure 3.851 and its exceptions to the one-year time limitation.
- Whether the circuit court abused its discretion by denying Hamilton's demands for additional public records under Florida Rule of Criminal Procedure 3.852(i).
Holdings
- The successive postconviction motion was untimely because it was filed after the one-year limitation period and neither the newly discovered facts, retroactive constitutional right, nor postconviction-counsel-neglect exception applied.
- The circuit court did not abuse its discretion in denying Hamilton's demands for additional public records because the requests were of questionable relevance, unlikely to lead to discoverable evidence, and were not shown to relate to a colorable postconviction claim.
Key quotations
“But Hurst has never been held to be retroactive to defendants in Hamilton’s position.” (at 278)
“We find no abuse of discretion in the denial of the requests and conclude that Hamilton has failed to meet his burden to demonstrate that the records sought relate to a colorable claim for postconviction relief.” (at 279)
Factual background
Hamilton was convicted of four offenses arising from the 1994 killing of Carmen Gayheart and received a death sentence after a ten-to-two jury recommendation for death. His convictions and sentence became final in 1998 after the United States Supreme Court denied certiorari. In 2016, Hamilton filed a successive postconviction motion asserting institutional failures and an unconstitutional death sentence under Hurst v. Florida, along with demands for additional records concerning prior postconviction counsel and the trial judge's judicial candidacy and tenure.
Procedural history
Hamilton was convicted and sentenced to death for first-degree murder, armed sexual battery, armed robbery, and armed kidnapping. The Florida Supreme Court affirmed on direct appeal and later affirmed the denial of his initial postconviction motion and denied habeas relief. The circuit court summarily denied Hamilton's successive postconviction motion as untimely and denied his public-records requests; the Florida Supreme Court affirmed.