Ernest D. Suggs v. State of Florida

Summary

The Supreme Court of Florida affirmed the summary denial of Ernest D. Suggs’s third and fourth successive motions for postconviction relief under Florida Rule of Criminal Procedure 3.851. The court held that his claims under Jones, Brady, Giglio, and Massiah were untimely or procedurally barred and, in several instances, also lacked merit. The court likewise rejected Suggs’s due process challenge to an earlier appellate decision.

Holdings

1. The circuit court properly summarily denied the successive postconviction motions because the claims were legally insufficient, untimely, procedurally barred, or meritless; no evidentiary hearing was required.
2. To obtain an evidentiary hearing on a newly discovered evidence claim, a defendant must allege facts showing that the evidence was unknown at trial and could not have been discovered through due diligence, and that the evidence would probably produce an acquittal on retrial.
3. Suggs's Jones, Brady, Giglio, and Massiah claims were untimely or procedurally barred under Rule 3.851 because the factual bases were known or discoverable years earlier, or the claims had previously been raised and rejected.
4. Suggs failed to establish Brady violations because he did not show that the alleged confessions occurred before trial or that the State knew of them at trial, and his claims based on alleged false testimony were untimely and procedurally barred.
5. The Giglio and Massiah claims were procedurally barred because Suggs had previously raised and litigated the same claims in his initial postconviction proceeding.
6. A circuit-court postconviction motion is not a proper vehicle for seeking relief from a prior Supreme Court of Florida decision.

Questions Presented

1. Whether the circuit court erred by summarily denying Suggs's successive postconviction motions without an evidentiary hearing.
2. Whether the alleged confessions of another murderer constituted newly discovered evidence satisfying Florida's Jones test and Rule 3.851's timeliness exception.
3. Whether evidence concerning alleged false testimony and prosecutorial misconduct established timely and meritorious Jones or Brady claims.
4. Whether Suggs's Giglio and Massiah claims were barred because they were previously raised, rejected, or could have been raised earlier.
5. Whether a circuit-court postconviction motion could provide relief from an earlier Supreme Court of Florida decision based on an alleged due process violation.

Disposition

affirmed