Bell v. State
Annotate this Case
The Supreme Court affirmed the circuit court's summary denial of Appellant's second successive motion for postconviction relief, holding that the petition was both untimely and procedurally barred.
Appellant was convicted of first-degree murder and sentenced to death. Several years later, Appellant filed his second successive motion for postconviction relief under Fla. R. Crim. P. 3.851, arguing that, in Buck v. Davis, 137 S. Ct. 759 (2017), the United States Supreme Court established a new fundamental constitutional right that the injection of racial bias and prejudice into a criminal trial constitutes per se ineffective assistance of counsel. Further, Appellant argued that this right applies to convictions and sentences, like his, that became final before Buck. The Supreme Court disagreed, holding (1) Appellant's motion was untimely because Buck did not establish a new right; and (2) because this Court previously addressed the arguments at issue and held that they did not warrant relief Appellant's motion was procedurally barred.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.