Bates v. State
In a capital postconviction appeal, Bates sought to interview a juror decades after his 1983 trial based on a newly-discovered alleged familial connection between the juror and the victim's family. The Florida Supreme Court affirmed denial of the motion as time-barred under Rule 3.575, holding that Bates failed to carry his burden of establishing good cause for the 40-year delay because he never specified when he actually learned of the alleged relationship.
Key facts
- Bates was convicted and sentenced to death in 1983; decades later, he sought to interview a juror based on an alleged newly-discovered familial connection between the juror and the victim's family.
- Bates filed his motion to interview the juror approximately 40 years after his trial verdict, without explaining when he actually learned of the alleged relationship.
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Why it matters
This opinion fills a gap in the limited case law construing Rule 3.575's 'good cause' standard by squarely placing the burden on the defendant to show precisely when he learned of juror-related information justifying a… — full analysis with a trial
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