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Richard E. Lynchv.Secretary, Florida Department Of Corrections, et al.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.12-15188
DecidedJanuary 8, 2015
Reporter776 F.3d 1209; 2015 WL 108623; 2015 U.S. App. LEXIS 307
JudgesUnited States Court of Appeals for the Eleventh Circuit; Chief Judge Ed Carnes and Circuit Judges Tjoflat and Jordan; Chief Judge Carnes authored the opinion
Tags
CriminalCriminal ProcedureDeath PenaltyHabeas CorpusSixth AmendmentIneffective Assistance of CounselEvidenceMirandaReversal
Case Summary

Richard Lynch was sentenced to death in Florida for murdering Morgan and her 13-year-old daughter, after stalking Morgan and carrying out a planned armed attack. The federal district court granted habeas relief on Lynch’s claim that counsel were ineffective in advising him to waive a jury at the capital sentence stage, but denied three other ineffective-assistance claims. The Eleventh Circuit applied AEDPA deference and held that the Florida Supreme Court reasonably rejected Lynch’s claim that counsel should not have advised him to plead guilty, because the evidence of guilt was overwhelming and he could not show that he would have insisted on trial. It also rejected the challenge to counsel’s failure to suppress a murder-suicide letter because the state court reasonably found consent and plain view, and rejected the brain-impairment investigation claim because the new evidence did not establish a reasonable probability of a different capital-sentencing balance. As to the sentence-stage jury waiver, the court assumed without deciding that Hill v. Lockhart supplied the prejudice standard and held that the state court reasonably concluded that the additional mitigation evidence would not have made a jury more favorable than the experienced sentencing judge. The court therefore reversed the grant of habeas relief and affirmed the denial of relief on Lynch’s other claims.

Opinion

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