King v. State
Annotate this CaseAfter a jury trial, Defendant was convicted of first-degree murder, involuntary sexual battery, and kidnapping. After a Spencer hearing, the trial court sentenced Defendant to death. The Supreme Court affirmed Defendant’s convictions and sentences. Defendant later filed a motion to vacate judgment and sentence pursuant to Fla. R. Crim. P. 3.851, alleging, inter alia, ineffective assistance of trial counsel. The postconviction court granted an evidentiary hearing on these two claims and then denied relief on all claims. Defendant appealed. Thereafter, the United States Supreme Court issued its decision in Hurst v. Florida, which held that the capital sentencing scheme in Florida violated the Sixth Amendment. The Supreme Court affirmed, holding (1) Defendant failed to demonstrate that counsel rendered ineffective assistance; (2) Defendant’s challenges to Florida’s execution procedures were meritless, and Defendant’s claim regarding his potential future incompetency was not ripe; and (3) any Hurst error that occurred during sentencing was harmless beyond a reasonable doubt.
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