Walton v. State
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The Supreme Court affirmed the postconviction court’s denial of Jason Walton’s motion to vacate sentences of death under Fla. R. Crim. P. 3.851 and denied Walton’s petition for writ of habeas corpus.
Walton was convicted and sentenced to death for the murders of three individuals that occurred during the commission of a robbery and burglary. This appeal concerned Walton’s fourth successive postconviction motion, in which Walton asserted that changes in Florida’s capital sentencing law were part of the cumulative review of new discovered evidence. The postconviction court denied the motion. Walton appeal and also filed a petition for habeas relief. The Supreme Court affirmed the denial of postconviction relief, holding that Walton’s claim that a proper Swafford/Hildwin cumulative analysis requires consideration of all changes in the law that might apply if a new trial were granted, as well as Walton’s other claims, was meritless. The Court then denied habeas relief, holding that Hurst v. State, 202 So. 3d 40 (Fla. 2016), did not apply retroactively to Walton’s sentences of death.
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