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Date: 01-12-2021
Case Style:
Joel Dale Wright v. State of Florida
Case Number: SC19-2123
Judge: PER CURIAM.
Court: Supreme Court of Florida
Plaintiff's Attorney: Ashley Moody, Attorney General, Tallahassee, Florida, and Doris Meacham,
Assistant Attorney General, Daytona Beach, Florida
Defendant's Attorney:
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Description:
Tallahassee, FL - Criminal defense attorney represented Joel Dale Wright with appealing an order of the circuit court denying his successive postconviction motion filed pursuant to Florida Rule of Criminal Procedure 3.851.
In 1983, Wright was convicted of first-degree murder, sexual battery,
burglary of a dwelling, and second-degree grand theft. He was sentenced to death.
Wright v. State, 473 So. 2d 1277 (Fla. 1985). His death sentence became final
when the United States Supreme Court denied certiorari review on January 21,
1986. Wright v. Florida, 474 U.S. 1094 (1986). This Court subsequently affirmed
the denial of Wright’s first three postconviction motions. Wright v. State, 581 So.
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2d 882 (Fla. 1991); Wright v. State, 857 So. 2d 861 (Fla. 2003); Wright v. State,
995 So. 2d 324 (Fla. 2008).
In 2017, Wright filed a third successive postconviction motion raising claims
based on the retroactivity of Hurst v. Florida, 577 U.S. 92 (2016), Hurst v. State,
202 So. 3d 40 (Fla. 2016), and chapter 2017-1, Laws of Fla.1 He now appeals the
denial of his most recent postconviction claims.
ANALYSIS
The crux of Wright’s argument on appeal is that this Court’s decision in
Hurst v. State established a new offense—capital first-degree murder—and that the
jury sentencing determinations described in Hurst are “elements” of that new
offense. From that assertion, Wright insists that Hurst created a substantive rule of
law that dates back to Florida’s original capital sentencing statute, thereby
requiring Wright’s death sentence to be vacated on the ground that certain
elements of his crime were never found by a jury.
We rejected a similar argument in Foster v. State, 258 So. 3d 1248, 1251
(Fla. 2018). As we explained in Foster, there is no independent crime of “capital
first-degree murder”; the crime of first-degree murder is, by definition, a capital
crime, and Hurst v. State did not change the elements of that crime. Id. at 1251-52
1. Chapter 2017-1, Laws of Florida was a legislative enactment by which
Florida’s capital sentencing statute was amended to require jury sentencing
determinations of the kind described in Hurst v. State.
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(holding that when a jury makes Hurst determinations, “it only does so after a jury
has unanimously convicted the defendant of the capital crime of first-degree
murder”).
Moreover, “[w]e have consistently applied our decision in Asay [v. State,
210 So. 3d 1 (Fla. 2016)], denying the retroactive application of Hurst v. Florida
as interpreted in Hurst v. State to defendants whose death sentences were final
when the Supreme Court decided Ring v. Arizona, 536 U.S. 584 (2002).”
Hitchcock v. State, 226 So. 3d 216, 217 (Fla. 2017). Wright echoes other pre-Ring
defendants who have advanced myriad legal theories that, in the end, turn on pleas
for a retroactive application of Hurst. But this Court has rejected such arguments,
however styled. See, e.g., Lambrix v. State, 227 So. 3d 112, 113 (Fla. 2017)
(rejecting arguments based on “the Eighth Amendment,” “denial of due process
and equal protection,” and “a substantive right based on the legislative passage of
chapter 2017-1, Laws of Florida”).
Finally, Wright offers an extensive critique of this Court’s decision in State
v. Poole, 297 So. 3d 487 (Fla. 2020), where we partially receded from Hurst. We
need not address Poole here, however, because Wright’s claims fail even under our
pre-Poole jurisprudence on Hurst and retroactivity.
Outcome: For these reasons, we affirm the trial court’s denial of postconviction relief.
Plaintiff's Experts:
Defendant's Experts:
Comments: