Scott Mansfieldv.Secretary, Doc
Scott Mansfield was convicted and sentenced to death in Florida for murdering Sara Robles. Police interrogated him at the station without giving Miranda warnings, and the trial court admitted the videotape over his objection. The Florida Supreme Court recognized the Miranda violation but held it harmless beyond a reasonable doubt. On federal habeas review, the district court granted relief, finding that the state court's harmless-error decision was unreasonable and that the videotape prejudiced the verdict. The Eleventh Circuit reversed. Applying the Brecht standard, the court held that the error was harmless because the videotape contained no confession, Mansfield repeatedly denied the murder, and other evidence strongly placed him with Robles near the time of death. That evidence included eyewitness testimony, Mansfield's pager near the body, food stamps found in his room, a ring whose pattern was consistent with an injury to Robles's neck, and testimony about a jailhouse confession and post-murder swimming. The court also held that the district court failed to defer properly to factual findings credited by the Florida Supreme Court. It reversed the judgment granting habeas relief and remanded with instructions consistent with that disposition.
Loading published copy…

