Marquardt v. State
Annotate this CaseAfter a jury trial, Defendant was convicted of two counts of first-degree murder and burglary of a dwelling with a firearm. The trial court sentenced Defendant to death for the two murders. The Supreme Court affirmed Defendant’s convictions and death sentences, holding (1) the trial court did not commit error in its evidentiary rulings; (2) no fundamental error occurred in the trial court’s placement of certain restrictions on Defendant’s presentation of his case; (3) the prosecutor did not improperly comment on Defendant’s guilt in front of the jury; (4) the trial court did not err in finding certain aggravating circumstances; (5) there was sufficient evidence to support the convictions; (6) the death sentences were proportionate; and (7) the trial court did not violate the attorney-client privilege by appointing Defendant’s standby counsel and investigators to present mitigation. The Court also prospectively modified the principles and procedures articulated in Muhammad v. State to the limited extent that trial courts should utilize an independent, special counsel, rather than standby counsel, to present mitigation evidence even when the defendant waives mitigation - as was done in this case.
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