Background
A man convicted of first-degree murder and sentenced to death had already seen his conviction affirmed and his case sent back for a new sentencing proceeding, which resulted in a second death sentence that was also affirmed. In 2023, he filed another round of postconviction proceedings, this time attaching three affidavits from former jailhouse witnesses. The trial court held an evidentiary hearing, concluded the witnesses were not credible, and denied relief.
What the Court Decided
The Florida Supreme Court affirmed the denial of relief. The court reviewed three issues: whether the jailhouse witness affidavits qualified as newly discovered evidence, whether trial counsel was ineffective during the penalty phase, and whether the newly discovered evidence undermined confidence in the death sentence.
On the newly discovered evidence question, courts apply a two-step test. First, the evidence must be something the defendant and their attorney genuinely did not know about at the time of trial. Second, the evidence must be strong enough that it would probably produce a different result on retrial—in a death penalty case, that means a life sentence instead of death. Here, the affidavits failed that standard because the postconviction court found the witnesses simply were not believable.
On the ineffective assistance claim from the penalty phase, the court applied the familiar two-part test requiring a defendant to show both that counsel performed deficiently and that the deficiency caused actual prejudice.
Why This Matters
This decision touches on two of the most frequently litigated issues in capital postconviction cases: the standard for newly discovered evidence and ineffective assistance claims during the penalty phase. A key takeaway is that credibility findings made by the postconviction court carry significant weight on appeal—if the judge who heard the witnesses did not believe them, the appellate court is unlikely to second-guess that conclusion. For capital defendants pursuing postconviction relief, the quality and credibility of supporting witnesses can be just as important as the legal theory itself.
Read the full opinion: Rhodes v. State, Florida Supreme Court — search the Florida Supreme Court opinions database
How Sanchez Vaughn Trial Lawyers Can Help
If you or someone you love is facing a serious conviction—including a capital case—and new information has come to light, postconviction proceedings may still be available. At Sanchez Vaughn Trial Lawyers, we have experience reviewing cases for newly discovered evidence and evaluating whether prior counsel’s performance may have fallen short, including at the sentencing phase. We are here to help you understand every avenue for relief that may remain open.