Summary
The Supreme Court of Florida affirmed the denial of Chadwick Willacy’s successive motion for postconviction relief under Florida Rule of Criminal Procedure 3.851. The court held that his challenge to the prosecutor’s peremptory strike of a juror based on alleged racial reasons was procedurally barred, untimely, and not revived by Flowers v. Mississippi because Flowers did not establish a new constitutional right held to apply retroactively.
Topics
Practice areas
Questions Presented
- Whether Willacy could relitigate in a successive postconviction motion his prior challenge to the prosecutor's allegedly racially motivated peremptory strike of juror Payne.
- Whether Willacy's successive motion was timely under Florida Rule of Criminal Procedure 3.851(d).
- Whether Flowers v. Mississippi established a new constitutional right held to apply retroactively so as to qualify for the exception to Rule 3.851's one-year filing limit.
Holdings
- A claim challenging the prosecutor's allegedly racially motivated peremptory strike that was previously litigated and resolved against the defendant is procedurally barred from relitigation in a successive postconviction motion.
- Willacy's successive motion was untimely under Florida Rule of Criminal Procedure 3.851(d)(1).
- Flowers v. Mississippi did not establish a new constitutional right held to apply retroactively, so it did not provide an exception to the one-year filing deadline and did not entitle Willacy to postconviction relief.
Key quotations
“Claims raised and rejected in prior postconviction proceedings are procedurally barred from being relitigated in a successive motion.” (2)
“We simply enforce and reinforce Batson [v. Kentucky, 476 U.S. 79 (1986)] by applying it to the extraordinary facts of this case.” (2)
Factual background
Willacy challenged the prosecutor's peremptory strike of juror Payne as racially motivated. That challenge had previously been litigated during Willacy's direct appeal and successive postconviction proceedings. Willacy later filed another successive postconviction motion relying on Flowers v. Mississippi, but the circuit court found the motion procedurally barred, untimely, and without merit.
Procedural history
Willacy filed a successive postconviction motion asserting that Flowers v. Mississippi entitled him to relief based on the prosecutor's allegedly racially motivated peremptory strike of juror Payne. The circuit court denied the motion on August 12, 2020, finding it procedurally barred, untimely, and meritless. The Supreme Court of Florida affirmed.