Lawrence v. State
Decision Date | 29 October 2020 |
Docket Number | No. SC18-2061,SC18-2061 |
Parties | Jonathan Huey LAWRENCE, Appellant, v. STATE of Florida, Appellee. |
Court | Florida Supreme Court |
Andy Thomas, Public Defender, and Barbara J. Busharis, Assistant Public Defender, Second Judicial Circuit, Tallahassee, Florida, for Appellant
Ashley Moody, Attorney General, and Charmaine M. Millsaps, Senior Assistant Attorney General, Tallahassee, Florida, for Appellee
Jonathan Huey Lawrence appeals his sentence of death for the 1998 first-degree murder of Jennifer Robinson that was imposed in a 2018 resentencing proceeding. We have jurisdiction, see art. V, § 3(b)(1), Fla. Const., and affirm. As is more fully explained below, although Lawrence's original death sentence was determined to be proportional based on substantially the same evidence presented during the de novo resentencing proceeding at issue, Lawrence argues on appeal that his sentence of death is not proportional. The State argues that this Court is legally prohibited, by the Florida Constitution, from reviewing death sentences for comparative proportionality when that review is not authorized by statute. We agree with the State and hold that the conformity clause of article I, section 17 of the Florida Constitution forbids this Court from analyzing death sentences for comparative proportionality in the absence of a statute establishing that review.
In 2000, Lawrence pleaded guilty to principal to the first-degree murder of Robinson, conspiracy to commit first-degree murder, giving alcoholic beverages to a person under twenty-one, and abuse of a dead human corpse, and he was sentenced to death for Robinson's murder. Lawrence v. State , 846 So. 2d 440, 442 (Fla. 2003). Robinson's murder followed two separate criminal episodes in which Lawrence and his codefendant murdered one individual and attempted to murder another individual. See id. at 443 n.3. We detailed the facts of Robinson's murder on direct appeal, explaining that Lawrence and his codefendant, who was also convicted of first-degree murder and sentenced to death for Robinson's murder, carried out their crimes against Robinson in accordance with notes in Lawrence's handwriting:
Id. at 442-43 (footnotes omitted). On direct appeal, Lawrence appealed only his sentence of death, and we affirmed, id. at 446, including on the basis that Lawrence's death sentence was proportionate in comparison to other cases in which we have upheld the imposition of the death penalty, id. at 452-55.
We subsequently affirmed the denial of Lawrence's initial postconviction motion and denied his habeas petition. Lawrence v. State , 969 So. 2d 294, 315 (Fla. 2007).
Thereafter, the trial court granted Lawrence's successive postconviction motion, vacated his death sentence, and ordered a new penalty phase proceeding pursuant to Hurst v. State , 202 So. 3d 40 (Fla. 2016), receded from by State v. Poole , 297 So. 3d 487 (Fla. 2020).
Before the second penalty-phase proceeding, which is at issue here, began, Lawrence sent a handwritten letter to the trial court requesting that his death sentence be "reinstated," stating in pertinent part:
[M]ay I request to please have my death sentence reinstated? I've never wanted a new trial or anything to do with the Hurst hearing/ruleing [sic] and have been trying for ten years to have my last attorney ... drop all my appeals but he has completely ignored me and refused any form of communications with me until telling me my new attorney's names and that I'm to go ... for a new sentencing that I do not want. I'm guilty of all my charges and deserve my death sentence. I've had no intention of putting the families, friends and loved ones of the innocent people I deliberately helped murder through all these 20 long years of grief, suffering and loss, to have to indure [sic] more. They deserve justice and every amount of peace my death sentence and conclusion might give them.
Through appointed counsel, Lawrence subsequently moved to waive his rights to a penalty-phase jury, to present mitigation, and to challenge the State's evidence. After inquiring of Lawrence and hearing testimony from a doctor who had evaluated Lawrence and found him competent, the trial court found Lawrence's waivers to be knowing, intelligent, and voluntary. The trial court ordered a presentence investigation and appointed special counsel pursuant to Marquardt v. State , 156 So. 3d 464 (Fla. 2015), to assist it in considering available mitigation.
Thereafter, following the State's penalty-phase presentation and special counsel's presentation at a subsequent hearing that also served as a Spencer1 hearing, the trial court sentenced Lawrence to death, finding that the aggravating circumstances2 "greatly outweigh" the statutory and nonstatutory mitigating circumstances.3 In sentencing Lawrence to death, the trial court further found as follows:
On appeal, Lawrence argues that his death sentence is disproportionate in comparison to other cases in which the sentence of death has been imposed. The State urges us to recede from precedent holding that we must review the comparative proportionality of every death sentence to "ensure uniformity of sentencing in death penalty proceedings," Rogers v. State , 285 So. 3d 872, 891 (Fla. 2019), by reserving the death penalty "for only the most aggravated and least mitigated of first-degree murders." Id. at 892 (quoting Urbin v. State , 714 So. 2d 411, 416 (Fla. 1998) ); see also Fla. R. App. P. 9.142(a)(5) ( ). In support of its argument, the State contends that comparative proportionality review violates the conformity clause of article I, section 17 of the Florida Constitution. We agree with the State and write to explain why our precedent is erroneous and must yield to our constitution.
The conformity clause of article I, section 17 of the Florida Constitution provides that "[t]he prohibition against cruel or unusual punishment, and the prohibition against cruel and unusual punishment, shall be construed in conformity with decisions of the United States Supreme Court which interpret the prohibition against cruel and unusual punishment provided in the Eighth Amendment to the United States Constitution." The Supreme Court has held that comparative proportionality review...
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