David Joseph Pittman v. State of Florida

Summary

The Florida Supreme Court affirmed the summary denial of David Joseph Pittman’s fourth successive motion for postconviction relief and denied his motion to stay execution. The court held that his intellectual disability claim was untimely and procedurally barred under controlling Florida precedent, and rejected his due process and Eighth Amendment arguments. Justice Labarga dissented, maintaining his disagreement with the court’s retroactivity ruling concerning intellectual disability claims.

Holdings

1. Summary denial was proper because the motion, files, and records established that Pittman was not entitled to relief.
2. The intellectual-disability claim was untimely because Pittman was required to raise it no later than 60 days after October 1, 2004.
3. The claim was procedurally barred because Pittman had previously raised his intellectual-disability claim.
4. Due process did not require an additional hearing because Pittman had received the process due and failed to satisfy the standards for avoiding summary denial.
5. Adhering to Phillips did not result in an arbitrary or capricious application of the death penalty, and Florida's death-penalty scheme remained constitutionally sound.
6. Pittman was not entitled to a stay of execution because he had not shown substantial grounds upon which postconviction relief might be granted.

Questions Presented

1. Whether Pittman's fourth successive intellectual-disability claim was procedurally barred and untimely under Florida's capital postconviction rules.
2. Whether Pittman was entitled to an evidentiary hearing on his intellectual-disability claim.
3. Whether the denial of further proceedings violated due process or rendered the death penalty arbitrary and capricious under the Eighth Amendment.
4. Whether Pittman was entitled to a stay of execution.

Disposition

affirmed