Lynch v. FloridaAnnotate this Case
Lynch pled guilty to two counts of first-degree premeditated murder, one count of armed burglary of a dwelling, and one count of kidnapping, all stemming from the 1999 deaths of Morgan and her 13-year-old daughter. Lynch’s counsel recommended that he waive a penalty phase jury because a jury would be more emotional and unsympathetic to mitigation presented for the murder of a child than a seasoned trial judge. Lynch waived his right to a penalty phase jury. The court sentenced Lynch to death. The Supreme Court of Florida affirmed. In 2003, the U.S. Supreme Court denied Lynch’s petition for certiorari. The Supreme Court of Florida affirmed the denial of Lynch’s initial motion for postconviction relief and denied his petition for habeas corpus. The Eleventh Circuit affirmed the denial of Lynch’s petition for federal habeas relief and, in 2016, the Supreme Court denied Lynch’s petition for certiorari to the Eleventh Circuit. Lynch filed a successive motion for postconviction relief, citing Hurst v. State. The Supreme Court of Florida affirmed the denial of relief. Lynch is not entitled to Hurst relief in light of his valid waiver of a penalty phase jury. Lynch argued, that the test for prejudice under the Strickland standard for ineffective assistance has changed post-Hurst. The court stated that trial counsel is not required to anticipate changes in the law in order to provide effective legal representation.