MANUEL ANTONIO RODRIGUEZ, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE.
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Manuel Antonio Rodriguez sought postconviction relief under Hurst v. Florida, arguing that Florida's capital sentencing scheme violated due process by not requiring a jury finding that he was guilty of 'capital murder.' The Florida Supreme Court affirmed the denial of his motion, holding that his death sentences were valid under the law at the time they were imposed and that subsequent legislative amendments did not entitle him to relief.
Rodriguez is not entitled to Hurst relief because his three death sentences, imposed following unanimous jury recommendations for death, became final in 2000 and were valid under the law applicable at that time. The subsequent legislative amendments codifying Hurst requirements do not retroactively apply to entitle Rodriguez to relief.
[1] A prior denial of a postconviction appeal raising similar claims can act as a procedural bar to subsequent appeals raising those same claims.
[2] A defendant is not entitled to relief under Hurst v. …
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“we conclude that our prior denial of Rodriguez's postconviction appeal raising similar claims is a procedural bar to the claim at issue in this appeal, which in any event, does not entitle him to Hurst relief”
Establishes that the procedural bar from prior appeal prevents consideration of the current Hurst claim
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Join FLexlaw to unlock all legal intelligenceRodriguez received three sentences of death following jury recommendations for death. His sentences became final in 2000. Rodriguez filed a postconvic…
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*147We have for review Manuel Antonio Rodriguez's appeal of the postconviction court's order denying Rodriguez's motion filed pursuant to Florida Rule of Criminal Procedure 3.851. This Court has jurisdiction. See art. V, § 3(b)(1), Fla. Const.
Rodriguez's motion sought relief pursuant to the United States Supreme Court's decision in Hurst v. Florida , --- U.S. ----, 136 S.Ct. 616, 193 L.Ed.2d 504 (2016), and our decision on remand in Hurst v. State (Hurst ), 202 So.3d 40 (Fla. 2016), cert. denied , --- U.S. ----, 137 S.Ct. 2161, 198 L.Ed.2d 246 (2017). Rodriguez responded to this Court's order to show cause arguing why Hitchcock v. State , 226 So.3d 216 (Fla.), cert. denied , --- U.S. ----, 138 S.Ct. 513, 199 L.Ed.2d 396 (2017), and Rodriguez v. State , 237 So.3d 918 (Fla. 2018), petition for cert. filed , No. 18-6505 (U.S. July 2, 2018), should not be dispositive in this case.
After reviewing Rodriguez's response to the order to show cause, as well as the State's arguments in reply, we conclude that our prior denial of Rodriguez's postconviction appeal raising similar claims is a procedural bar to the claim at issue in this appeal, which in any event, does not entitle him to Hurst relief. See Foster v. State , No. SC18-860, 258 So.3d 1248, 2018 WL 6379348 (Fla. Dec. 6, 2018) ; Rodriguez , 237 So.3d at 919 ; Hitchcock , 226 So.3d at 217. We previously affirmed the postconviction court's denial of Rodriguez's claims for Hurst relief pursuant to Hitchcock . See Rodriguez , 237 So.3d at 919. In this case, relying on Hurst and the Legislature's amendments to Florida's capital sentencing scheme in response to Hurst pursuant to chapter 2017-1, Laws of Florida, Rodriguez contends that the elements of "capital murder" have existed since before Hurst and denying him relief amounts to a due process violation because he has not been found "guilty" of "capital murder." However, chapter 2017-1 codified the Hurst requirements, and, as we have previously explained, Rodriguez's three sentences of death were imposed following a jury's unanimous recommendations for death and became final in 2000. See Rodriguez , 237 So.3d at 919. Therefore, because Rodriguez is not entitled to relief under Hurst or the legislation implementing the rights recognized in Hurst , we affirm the denial of Rodriguez's motion. See Rodriguez , 237 So.3d 919 ; Hitchcock , 226 So.3d at 217.
The Court having carefully considered all arguments raised by Rodriguez, we caution that any rehearing motion containing reargument will be stricken. It is so ordered.
PARIENTE, LEWIS, QUINCE, POLSTON, LABARGA, and LAWSON, JJ., concur.
CANADY, C.J., concurs in result.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited (13 total)
- Hurst v. Florida., 136 S. Ct. 616 (U.S. 2016)
- Hurst v. State, 202 So. 3d 40 (Fla. 2016)
- Florida v. Hurst., 137 S. Ct. 2161 (U.S. 2017)
- Hitchcock v. State, 226 So. 3d 216 (Fla. 2017)
- Rainey v. Dist. Attorney Off. of Philadelphia., 138 S. Ct. 513 (U.S. 2017)
- Ward v. Neal, 137 S. Ct. 2161 (U.S. 2017)
- Boone v. Lorie Davis, 137 S. Ct. 2163 (U.S. 2017)
- Loud v. Lorie Davis, 138 S. Ct. 513 (U.S. 2017)
- Allen v. United States, 138 S. Ct. 513 (U.S. 2017)
- Foster v. State, 258 So. 3d 1248 (Fla. 2018)